Draft

Advisory Board on Radiation and Worker Health

National Institute for Occupational Safety and Health

Focused Review of ORAUT-RPRT-0092, Revision 00, and 

Remaining Petition SEC-00103 Evaluation Report Period: 

1991–2007

Contract No. 75D30119C04183

Document No. SCA-TR-2022-SEC001, Revision 0

Prepared by

Ron Buchanan, PhD, CHP

Joe Fitzgerald, MS, MPH

SC&A, Inc.

2200 Wilson Blvd., Suite 300

Arlington, VA 22201-3324

April 22, 2022 

DISCLAIMER

This is a working document provided by the Centers for Disease Control and Prevention (CDC) 

technical support contractor, SC&A for use in discussions with the National Institute for 

Occupational Safety and Health (NIOSH) and the Advisory Board on Radiation and Worker 

Health (ABRWH), including its Working Groups or Subcommittees. Documents produced by 

SC&A, such as memorandum, white paper, draft or working documents are not final NIOSH or 

ABRWH products or positions, unless specifically marked as such. This document prepared by 

SC&A represents its preliminary evaluation on technical issues.

NOTICE: This document has been reviewed to identify and redact any information that is

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SC&A, Inc. technical support for the Advisory Board on Radiation and Worker Health’s 

review of NIOSH dose reconstruction program

Document title Focused Review of ORAUT-RPRT-0092, Revision 00, and Remaining 

Petition SEC-00103 Evaluation Report Period: 1991–2007

Document number SCA-TR-2022-SEC001

Revision number 0 (Draft)

Supersedes NA

Effective date April 22, 2022 

Task manager Joseph Fitzgerald, MS, MPH [signature on file]

Project manager Bob Barton, CHP [signature on file]

Document reviewer(s) Bob Barton, CHP [signature on file]

Record of revisions

Revision number Effective date Description of revision

0 (Draft) 4/22/2022 Initial issue
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Table of Contents

List of Tables................................................................................................................... 4

List of Figures.................................................................................................................. 4

Abbreviations and Acronyms........................................................................................... 5

1 Executive Summary.................................................................................................. 7

2 Introduction............................................................................................................. 10

3 Background ............................................................................................................ 12

4 Review of WSRC Programmatic Assurance for Subcontractor Bioassays, 1991–

2007 .............................................................................................................................. 15

4.1 SRS internal monitoring dosimetry program procedural upgrades, 1991–200715

4.2 Realization of improvements to radiological monitoring programs, 1991–200719

4.3 Timetable of WSRC procedural upgrades and implementation, 1991–2007.... 23

5 Review of Subcontractor Job-Specific Bioassay Completeness and 

Representativeness, 1991–1998................................................................................... 26

5.1 Analysis of when RWPs specified radionuclides to be bioassayed.................. 26

5.2 Requiring only at least one bioassay versus requiring all mandated bioassays29

5.3 RPRT-0092 data versus 1997 SRS self-assessment....................................... 30

5.4 Analysis of compliance as a function of building for 1991–1998 ...................... 32

5.5 Analysis of noncompliance for 1991–1998....................................................... 36

6 Review and Overview of SEC-Related Issues, 1972–2007 .................................... 38

7 Summary Conclusions............................................................................................ 41

8 References ............................................................................................................. 44

Attachment A: Issues Matrix for SRS ............................................................................ 48

Attachment B: Updated Status of SEC-00103-Related Issues...................................... 72
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List of Tables

Table 1. Chronology of changes to policies and procedures and RWP bioassay data 

evaluation ........................................................................................................... 23

Table 2. Percent of RWP-specified radionuclide bioassays compared to total number of 

mandated radionuclide bioassays as listed in RPRT-0092, table C-1 ................ 28

Table 3. Breakdown by year of using all mandated radionuclides and using only at least 

one radionuclide for sCTWs directly monitored 1991–1998 ............................... 29

Table 4. Breakdown by year of using all mandated radionuclides and using only at least 

radionuclide for sCTWs effectively monitored 1991–1998.................................. 30

Table 5. Percent of directly bioassayed sCTWs working on RWPs for plutonium versus 

area and year ..................................................................................................... 33

Table 6. Percent of directly bioassayed sCTWs on RWPs for strontium/fission products 

versus area and year.......................................................................................... 34

Table 7. Percent of directly bioassayed sCTWs working on RWPs for uranium versus 

area and year ..................................................................................................... 35

Table 8. Percent of directly bioassayed sCTWs working on RWPs for americium versus 

area and year ..................................................................................................... 35

Table 9. Percent of directly bioassayed sCTWs working on RWPs for neptunium versus 

area and year ..................................................................................................... 36

Table A-1. March 2022 update of issues matrix for the SRS SEC petition and petition 

ER ...................................................................................................................... 50

Table B-1. Status Summary of SEC Actions: Savannah River Site (SEC-00103)......... 73

List of Figures

Figure 1. Fraction of total mandated bioassays that were listed on the RWP versus year

........................................................................................................................... 27

Figure 2. Figure 4-4 from RPRT-0092: attachment 2 to root cause analysis corrective 

action report........................................................................................................ 31

Figure 3. Percent of directly and effectively monitored sCTWs per RWP-mandated 

bioassays (R + A)............................................................................................... 32

Figure 4. Directly bioassayed radionuclides with 1991–1994 noncompliance fraction 

greater than 1995–1998 noncompliance fraction................................................ 37

Figure 5. Directly bioassayed radionuclides with 1991–1994 noncompliance fraction 

less than 1995–1998 noncompliance fraction .................................................... 37
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Abbreviations and Acronyms

ABRWH, Board Advisory Board on Radiation and Worker Health 

A assumed

Am americium

Am/Cm/Cf americium/curium/californium

bios bioassays

CFR Code of Federal Regulations 

DOE U.S. Department of Energy

DOE-SR DOE Savannah River Operations Office

CTW construction trade worker

DPSOL DuPont Savannah River Operating List 

DPSOP DuPont Standard Operating Procedure 

EEOICPA Energy Employees Occupational Illness Compensation Program Act

ER evaluation report 

EU enriched uranium 

FEB Facility Evaluation Board 

GAO U.S. General Accounting Office

HHS U.S. Department of Health and Human Services 

HQ headquarters 

JSB job-specific bioassay

mrem millirem

NA not applicable 

NIOSH National Institute for Occupational Safety and Health

Np neptunium 

NTS Noncompliance Tracking System

ORAUT Oak Ridge Associated Universities Team

PAAA Price-Anderson Amendments Act 

Pu plutonium 

Q2 second quarter 

R required 

RIP Radiological Improvement Program 

RCA radiologically controlled area
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RCO Radiological Control Operations 

RQB radiological qualifications badge

RU recycled uranium 

RWP Radiological Work Permit

sCTW subcontractor construction trade worker 

SAR safety analysis report

SEC Special Exposure Cohort 

Sr/FPs strontium/fission products 

SRDB Site Research Database

SRS Savannah River Site 

SRTC Savannah River Technology Center 

SRWP standing radiological work permit 

STC special tritium compound

U uranium 

WG work group 

WSRC Westinghouse Savannah River Company 
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1 Executive Summary

SC&A, Inc. reviewed the National Institute for Occupational Safety and Health (NIOSH) Special 

Exposure Cohort (SEC) Petition SEC-00103 evaluation report (ER) for the Savannah River Site 

(SRS) for the period 1991–2007. Following the designation of an SEC class for subcontractors 

1972–1990, this review encompasses the remaining years that were qualified for that SEC 

evaluation and also addresses any remaining SEC-relevant issues stemming from previous 

discussions of the SRS and SEC Issues work groups.

SC&A approached this review by considering to what extent the programmatic shortcomings 

that impaired job-specific bioassay monitoring at SRS during the prior SEC period were 

remedied by the major procedural upgrades undertaken by the new operating contractor, 

Westinghouse Savannah River Company (WSRC), and in what timeframe. Bioassay data 

completeness, itself, was addressed in terms of the degree to which job-specific bioassays were 

performed, either directly or effectively, in the context of the data sampling in ORAUT-RPRT0092, revision 00, “Evaluation of Bioassay Data for Subcontracted Construction Trade Workers 

at the Savannah River Site” (NIOSH, 2019a; “RPRT-0092”). Reconciling program assurance 

and data completeness measures is necessarily subjective: weighing when job-specific bioassay 

monitoring became reliable and complete enough that resulting datasets can be considered 

representative of subcontractor exposures. SC&A’s objective is to present the full scope of these 

considerations for work group deliberation, understanding that the actual weighing and balancing 

of them will ultimately be performed by the work group and the Advisory Board on Radiation 

and Worker Health (Board).

For program assurance, SC&A examined key elements of the job-specific bioassay monitoring 

program for which concerns were raised for the earlier SEC period (1972–1990). These include 

implementation of a functional Radiological Work Permit (RWP) program, reliable collection of 

job-specific bioassays, and sufficient facility source-term characterization to identify 

radionuclides of concern.

While RWPs were introduced in phases by corrective action following the Tiger Team 

assessment, beginning in mid-1990, and subsequently codified by procedure in 1992, SC&A 

finds that adequate implementation of these requirements was not apparent in the workplace until 

1994–1995. SC&A found that the fraction of required bioassays as listed on the RWPs rose from 

very few (less than 5 percent) in 1991–1993 to over 60 percent in 1994 and over 80 percent in 

1995. As with the earlier SEC period (1972–1990), NIOSH did not address all the radionuclides 

mandated for the RWP when determining data completeness for job-specific bioassay 

monitoring. Rather, the summary conclusions in NIOSH’s RPRT-0092 evaluation of 

subcontractor bioassay data (NIOSH, 2019a) assessed whether at least one radionuclide

mandated for an RWP had been monitored adequately, as shown in table 6-4 of that document. 

Therefore, the percentage of matching results for direct and effective monitoring appear to be 

overstated. This is most relevant for the 1991–1994 period, when many exposure-relevant 

radionuclides of concern were not yet included in RWPs (with the balance being predominately 

prescheduled), and inaccurate facility source term assumptions may have been made, as noted by 

the U.S. Department of Energy (DOE) in 1990 (DOE, 1990) and by WSRC in 1999 (WSRC, 

1999a). 
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Concerning co-exposure model datasets, SC&A’s focused review of plutonium coworker 

matches during the 1991–1998 WSRC period in RPRT-0092 found that, while nearly 96 percent 

of identified coworker matches involved the same RWP, inclusion of additional criteria (e.g., the 

same date, time, and craft) decreases this percentage significantly, down to 45 percent (SC&A, 

2019a, p. 60). Given the often nonroutine and intermittent nature of subcontractor construction 

trade worker (sCTW) jobs under RWPs, sometimes involving unique radiological source terms, 

SC&A believes that matching needs to be more closely aligned with what is cited on the actual 

RWP.

Notwithstanding the bioassay sampling matches provided for 1991–1998 in RPRT-0092 and the 

amount of routine bioassay data available for SRS, WSRC found, in 1997, that required jobspecific bioassays were not being submitted by most workers (e.g., 79 percent missing in the 

second quarter of 1997) (DOE, 1998a). Assuming that similar lapses in bioassay submission 

existed during the 1991–1996 timeframe (spanning from the initial 1990 Tiger Team findings 

about bioassay program noncompliance to the 1997–1998 WSRC actions in response to DOE 

field audits, internal Facility Evaluation Board (FEB) findings, and DOE headquarters 

enforcement action), RWP-required job-specific bioassay data should be assumed to be 

substantially incomplete for purposes of demonstrating monitoring data completeness and 

representativeness for use in a co-exposure model until the end of 1996. A 100-percent 

resampling of all workers on job-specific bioassays was performed for 1997, and enhanced 

accountability and tracking of job-specific bioassays were implemented in 1998.

While job-specific bioassays and source terms may be incomplete given these programmatic 

shortfalls, this is mitigated by considerations such as (1) job-specific bioassays made up only 

5 percent of total bioassays1

 and (2) a full resampling of job-specific bioassay results for the 

second quarter of 1997 found no evidence of intakes. Likewise, a sampling of RWPs during this 

same period indicates that many workers were either directly monitored or on the same RWP as 

an assumed coworker who was monitored, which resulted in their being effectively monitored. 

The majority of these monitoring results are presumably a result of enrollment in the routine 

program and thus do not obviate the deficiencies in completeness of the job-specific monitoring 

program. However, it must be determined if, and when, the observed coverage of the routine 

monitoring program is sufficient to justify the representativeness of any subsequent co-exposure 

model as applied to workers who should have been covered by the deficient job-specific 

program. 

1

 As found by a WSRC self-assessment of the internal monitoring program participation for the first four months

of 1997, although this one-time sampling is not necessarily applicable to earlier years (DOE, 1998a).

One potential SEC question that persists is the appropriate scope of construction trade workers 

(CTWs) that can and should be addressed by existing co-exposure models. The distinction 

between sCTWs and CTWs in terms of work activities and exposure potential has been 

sometimes clouded during recent deliberations before the work groups. NIOSH concluded that 

“the exposure conditions and the potential for intakes were similar among all CTWs (prime and 

subcontractor), therefore a combined strata [for co-exposure modeling] is appropriate” (NIOSH, 

2020a, slide 21). SC&A contended that subcontractor radiological work would have been more 

intermittent and transitory in nature and likely involved more nonroutine, high-exposure 
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activities and source terms. Overall, the lack of compliance with the program that should have 

provided job-specific bioassay monitoring would have impacted CTWs on job plans and RWPs, 

the same as for sCTWs. From an exposure potential standpoint, should CTWs on permitdirected, job-specific bioassays be within the scope of SEC consideration? While the nature of 

subcontractor work under RWPs was compelling as a basis for the SEC recommendation for 

1972–1990, the programmatic and operational circumstances of broader CTW exposure potential 

during 1991–2007 needs to be reexamined for consistency. 

Regarding other SEC-relevant issues for SEC-00103, SC&A has found no outstanding issues 

other than several remaining action items for work group discussion and closure from previous 

issues matrices (these are listed and updated in attachments A and B).
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2 Introduction

SC&A was tasked by the Board’s SRS Work Group on September 21, 2021, to review NIOSH’s 

SEC-00103 ER for the period 1991–2007, with a focus on remaining SEC-related issues 

stemming from RPRT-0092 (NIOSH, 2019a). The Board recommended, and the Secretary of 

Health and Human Services (HHS) approved, that an SEC be designated for: 

All construction trade employees of Department of Energy subcontractors 

[excluding employees of the following prime contractors who worked at the 

Savannah River Site in Aiken, South Carolina, during the specified time periods: 

E. I. du Pont de Nemours and Company, October 1, 1972, through March 31, 

1989; and Westinghouse Savannah River Company, April 1, 1989 through 

December 31, 1990], who worked at the Savannah River Site from October 1, 

1972, through December 31, 1990, for a number of work days aggregating at least 

250 work days, occurring either solely under this employment or in combination 

with work days within the parameters established for one or more other classes of 

employees included in the Special Exposure Cohort. [ABRWH, 2021, p. 1; HHS, 

2021, p. 2] 

The basis for this recommendation for 1972–1990 acknowledged that subcontractors conducted a 

broad range of work activities at SRS and may have worked in high-contamination and highairborne-radioactivity areas and may have been utilized for short-term high-exposure work tasks 

(ABRWH, 2021). It was also found that subcontractors may have been “transient” and 

“intermittently tasked with nonroutine radiological jobs under work permits, and thus were not 

likely enrolled in the routine (including termination) bioassay monitoring program” (ABRWH, 

2021, p. 1). The Board also found there to be “insufficient information, including a lack of jobspecific radio-bioassay monitoring data for subcontractor construction trade workers, and 

assurance of workplace monitoring and source term data, to enable NIOSH to estimate with 

sufficient accuracy all potential internal doses” (ABRWH, 2021, p. 2).

The purpose of this review is to assess these same programmatic and bioassay data adequacy 

issues for post-1990 operations at SRS, during the balance of years covered by NIOSH’s ER

(1991–2007) for the SEC-00103 petition, to ascertain whether these inadequacies may have 

persisted into that later time period and to assess to what extent, and to what point in time, dose 

reconstruction with sufficient accuracy may have been affected.

SC&A revised the last SEC issues matrix (SC&A, 2014a) compiled for the work group to update 

the status of the remaining SEC-relevant issues. This matrix was issued as a memorandum to the 

SRS and SEC Issues work groups on March 11, 2022 (SC&A, 2022), and is reproduced for 

convenience here as attachment A. 

SC&A also addressed the status of remaining SEC-00103 issues that remain before the work 

group, including those stemming from the co-exposure model reviews and radionuclide-specific 

issues (e.g., neptunium, thorium, and metal hydrides). NIOSH and SC&A have already 

exchanged reviews and responses for these issues and await work group discussion and closure. 
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SC&A provided the work groups an internal status update for these issues in a matrix on 

October 25, 2021 (SC&A, 2021), reproduced here for convenience as attachment B.2

2

 Note that the attached version of the matrix has been modified slightly for accuracy following a subsequent 

conference call meeting between SC&A and NIOSH on January 12, 2022. 
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3 Background

As emphasized by SC&A in its past reports and presentations, the period of time between the 

mid-1980s and early 1990s was one of rapid operational, policy, and program changes at SRS, as 

well across DOE’s other nuclear facilities. In response to external events, such as the Chernobyl 

nuclear accident in 1986 and outside scrutiny of the environmental protection compliance of its 

operations, DOE opened its facilities to independent regulation on the environmental side and 

developed updated environment, safety, and health directives, including DOE Order 5480.11, 

“Radiation Protection for Occupational Workers,” in 1988. This was coupled with independent 

DOE headquarters assessments for safety and health, including DOE-wide audits beginning in 

the mid-1980s, followed by headquarters-managed Tiger Teams that audited environment, 

safety, and health program compliance beginning in 1989. At the same time, Congress held a 

series of hearings and investigations about the conduct of nuclear and radiological safety 

programs at DOE’s nuclear facilities, culminating in legislation forming external oversight 

bodies for DOE nuclear facility oversight, consisting of the Advisory Committee on Nuclear 

Facility Safety in 1987, which was supplanted in 1998 by the Defense Nuclear Facilities Safety 

Board. The Price-Anderson Act was amended in 1988 to establish a formal regulatory 

enforcement program for nuclear facility safety within DOE, to be administered by an 

independent headquarters office. The implementation of a DOE-wide enforcement program 

ushered in a regulatory version of the DOE occupational radiation protection directive, Title 10 

of the Code of Federal Regulations (CFR) Part 835, which was promulgated in 1995. 

At SRS, during this same time period, these major departmental changes were compounded by 

unprecedented changes in site operations, management, and policy. Following an anomalous 

spike in reactor power during startup of P Reactor in 1988, internal investigations and 

congressional oversight hearings led to shutdown of and upgrades to the SRS production reactors 

through the early 1990s. With the end of the Cold War, the tritium production mission of SRS 

was replaced by other missions, including those of facility decontamination and 

decommissioning, waste management, and expanded research. These changing and expanded 

missions prompted the influx of increasingly large complements of outside sCTWs, which 

peaked in the late 1980s to early 1990s. 

DuPont ended its 38-year contractual management of the SRS site on April 1, 1989, and WSRC

became the operating contractor (with Bechtel as the construction management contractor). On 

the heels of the Tiger Team assessment of SRS in early 1990, WSRC embarked on a 

Radiological Improvement Program (RIP) to revise sitewide radiation protection procedures, 

expand the qualifications and training of personnel, and improve actual workplace safety 

compliance. The scope of the RIP, begun in late 1990, encompassed functions of the radiological 

monitoring program critical to the SEC-related questions at hand. These included RWPs, jobspecific bioassays, termination bioassays, facility source-term characterization, and applying 

bioassay requirements to roving employees (those whose job assignments had them entering 

various radiological facilities).

WSRC was given a notice of violation and a civil penalty in 1998 under the Price-Anderson 

Amendments Act nuclear safety enforcement program. The citation was for “deficient work 

processes with respect to full worker adherence to established WSRC bioassay requirements” 

(DOE, 1998a, p. 1). DOE’s Office of Enforcement and Investigation found that:
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Specifically, workers and their management routinely failed, over a period of 

approximately two years, to ensure that job-specific bioassay samples were 

submitted for analysis as required by WSRC internal procedures. DOE-SR 

identified bioassay sample submittal deficiencies for the job-specific portion of 

the bioassay program to WSRC as early as November 1995. . . . In spite of these 

completed corrective actions that included numerous revisions to bioassay and 

work control procedures and worker retraining, worker participation in the jobspecific bioassay program continued to decline. These violations occurred 

because WSRC did not have a process in place to determine whether corrective 

actions had been effective in remedying identified deficiencies. As a consequence, 

the job-specific bioassay non-participation level rose to 79 percent in the second 

quarter of 1997. [DOE, 1998a, pp. 1–2; emphasis added] 

This notice of violation originated in a self-assessment conducted by WSRC in May 1997, 

subsequent to its initial findings in 1995, following DOE enforcement actions in 1997 at Mound 

Laboratory for a similar lack of adherence to job-specific bioassays. The intent was to determine 

if similar problems existed with the bioassay program at SRS (Augusta Chronicle, 1998). WSRC 

conducted its earlier, limited sampling of facilities using job-specific RWPs requiring bioassay 

samples and found that: 

Of the 3,200 bioassay requirements reviewed, 95 percent of the workers were 

covered by the routine bioassay program and had submitted bioassay samples as 

required. However, of the 5% of the workers requested to submit job-specific 

bioassay samples, only 33% [non-participation rate of 67%] were provided. A 

separate review also found that the Bioassay Laboratory was only notified by the 

Radiological Control Operations (RCOs) of about 33% of the samples that were 

actually submitted for analysis. [Cite redacted] 

As noted in its initial review of job-specific bioassay data completeness in 2017, SC&A found 

that “the problem of worker and management adherence to job-specific bioassay requirements 

was a persistent one, as far back as to the 1990 Tiger Team assessment” (SC&A, 2017, p. 17).

Corrective actions tied to the Tiger Team assessment in 1990, and later WSRC findings in 1995 

and 1997, proved inadequate to change the workplace culture and accountability to bioassay 

participation. WSRC’s later corrective actions included extensive revision of existing procedures 

to strengthen accountability measures for job-specific bioassays, to expand worker training, and 

to develop lines of inquiry to be added to WSRC self-assessments of safety and health operations 

([redacted]). 

The timing and realization of these upgrades provide the basis for programmatic assurance that 

subcontractors performing radiological work under a permit would have been appropriately 

bioassayed for radionuclides for which they had an internal intake potential. Realization is used 

here to contrast with mere implementation, because the longstanding DuPont era workplace 

safety culture surrounding radiological controls at SRS would not have changed immediately 

with either the advent of a new operating contractor or implementation of the RIP. Instead, it was 

recognized by both DOE and WSRC as a long-term process that would take some years before 

being realized (GAO, 1990). This question—when and how SRS radiological monitoring of 

sCTWs became adequately reliable and complete in the 1990s for purposes of dose 
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reconstruction under the Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA)—is addressed in the following sections from a programmatic and data completeness 

standpoint. 
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4 Review of WSRC Programmatic Assurance for Subcontractor 

Bioassays, 1991–2007

4.1 SRS internal monitoring dosimetry program procedural upgrades, 1991–

2007

A detailed summary of the evolution of policies and procedures during most of the early years of 

this period (1971–1999) can be found in section 3.0 of NIOSH’s report, ORAUT-RPRT-0091, 

revision 00, “Evaluation of Savannah River Site Americium-241 Source Terms Between 1971 

and 1999 Using Bioassay Frequency Tables” (NIOSH, 2019b; “RPRT-0091”). For SRS 

facilities, WSRC prescribed a system of routine, special, and job-specific bioassay monitoring,3

with worker categories, frequencies, and facility areas defined in the successive revisions of 

DuPont’s DPSOL 193-302 beginning in the 1960s (DPSOL 193-211 in 1988) and in Manual 

5Q1.1, beginning in 1992. Construction Division workers were not required to use the bioassay 

sample frequency tables and had more general requirements until the initial 1992 Manual 5Q1.1 

procedures were implemented, upon which in vitro and in vivo bioassay procedures were applied 

in the same manner to all SRS workers (WSRC, 1992, p. 28). 

3 By the late-1990s WSRC era at SRS, the routine bioassay program was defined in two parts: “The 

pre-scheduled sampling program includes workers who routinely work in locations with Airborne Radioactivity 

Area postings. They are sampled twice annually, based on their birthday, for those radionuclides they routinely 

encounter. . . . The job-specific sampling program is for workers not on a routine program, or whose routine 

program does not cover all the radionuclides to be encountered, but who need to enter locations requiring 

respiratory protection” (WSRC, 1998a, p. 1; emphasis added).

The following are policy and procedural milestones in the WSRC bioassay program relevant to 

the question of nonroutine, job-specific bioassay data completeness after 1990.

Radiological Work Permits (RWPs). SC&A (2019a) noted in its review of RPRT-0092 that: 

The RWP program was discontinued in the 1960s by DuPont in favor of applying 

internal DPSOL procedures, but as a DOE assessment pointed out, a requirement 

for RWPs and SRWPs [standing RWPs] for any work within a radiologically 

controlled area (RCA) was carried forward as cited in Special Hazards Bulletins 

in DPSOP 40, revision 82, September 1989. As DOE observed, “Radiation Work 

Permits or Standing Radiation Work Permits are not used even though required by 

Westinghouse Savannah River Company procedures and accepted industry 

standards” (DOE, 1990, p. 4-307). [SC&A, 2019a, p. 34] 

In response, WSRC began phasing in its RWP procedures across SRS in the 1990–1991 

timeframe, although it is not clear how and on what timeframe that implementation was carried 

out (WSRC, 1990a). Notably, there was only one RWP identified in RPRT-0092 for 1990, with 

increasing numbers in 1991. The RWP procedures were subsequently codified in the initial 1992 

version of WSRC Manual 5Q1.1. The importance of a sitewide, fully functional RWP program 

cannot be overstated. Without RWPs, there would not have been an accountable and deliberative 

process by which potential nonroutine radiological hazards, including unique radionuclide source 

terms, would have been assessed to determine what job-specific bioassays would have been 
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warranted to adequately monitor the worker for potential job-specific intakes. Without necessary 

job-specific bioassays being specified, the resulting data (i.e., bioassay dataset) would be 

incomplete and not necessarily representative of the potential exposures attendant to nonroutine 

radiological work being conducted at SRS. 

Roving employee coverage. Notable in the initial 1992 version of Manual 5Q1.1 is a new 

guideline defining some workers as “Roving Employees,” whose “job assignment requires them 

to enter RCAs in different facilities across the Site during the course of their regular work” 

(WSRC, 1992, PDF p. 37). This new definition specifically included site support personnel and 

subcontractors, who by the nature of their work and craft tended to move from location to 

location at SRS. For the first time, it was required that such workers be categorized for bioassay 

type and frequency according to which SRS facilities they spent the majority of their time and be 

placed on a “composite” bioassay program (WSRC, 1992, PDF p. 37). Before this new 

procedure, it had been up to individual facility managers to determine whether and what bioassay 

requirements would apply to such transient workers in their facilities, leading to potential 

inconsistencies in bioassay coverage in terms of source terms, type, and frequency. A fully 

implemented RWP program, coupled with a computer-controlled access system in 2003/2004, 

made it feasible to ascertain which workers were monitored and in what location (LaBone & 

Findley, 2013). 

Respiratory protection linkage. Another explicit requirement was added in the Routine 

Bioassay Program Assignment section of Manual 5Q1.1, revision 0, which entailed that 

“Personnel who wear respiratory protection or who work in posted Contamination or Airborne 

Radioactivity Areas must be sampled for the nuclide to which they are potentially exposed, via 

either the routine sampling program or non-routine, job-specific sampling program” (WSRC, 

1992, PDF p. 60). This was the first formal referencing of a requirement that linked respiratory

protection use with the need for either routine bioassays or nonroutine, job-specific bioassays. 

Job-specific bioassays. WSRC considered it also necessary to include, in the initial 5Q1.1 

manual, an admonition about the importance of performing nonroutine, job-specific bioassays 

and combining them with the routine bioassay program: 

Caution: It is EXTREMELY IMPORTANT to note that the effectiveness of the 

bioassay program in general depends on combining both the routine 

and the non-routine, job-specific program. Any time unusual events 

occur, or jobs are performed that may expose personnel to unusual 

hazards, a job-specific program should be considered per 

Section 5.1.2.1. [WSRC, 1992, PDF p. 36] 

As noted in SC&A’s review of RPRT-0092, “Without job-specific bioassays to complement the 

required plutonium, tritium and fission product routine bioassays, “roving” construction workers 

would not have been adequately enrolled for the radionuclides to which they may have been 

potentially exposed, and the bioassay database for both CTWs and subCTWs would accordingly 

be incomplete” (SC&A, 2019a, p. 21). Regarding reliance on the routine bioassay program, 

WSRC made it clear that unique job-related radiological sources entailed job-specific bioassay 

sampling: 
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It is very important to realize that being on a routine sampling program does not 

automatically cover the bioassay sampling requirement specified on the RWP. In 

fact, section 5.2.4 of 5Q1.1, 504 “Radiological Work Permit” used to require that 

the radiological control supervisor identify the RWP bioassay requirements so 

that they were consistent with 5Q1.1, 506 “In Vivo and In Vitro Bioassay 

Scheduling and Administration.” This link was eliminated because routine 

sampling programs may not be appropriate for work involving non-routine mixes 

or concentrations of radioactive material. [Findley, 1997, p. 2] 

The distinction between routine and non-routine bioassay sampling is important to the question 

of bioassay data representativeness and whether and how SRS routine bioassay data can be 

substituted for what may be incomplete nonroutine bioassay data related to job-specific bioassay 

sampling. It also shows that WSRC continued to have programmatic shortcomings in how jobspecific bioassays were being implemented as late as 1997. 

Termination bioassays. Included in the initial 1992 5Q1.1 manual was an expanded procedural 

requirement for termination bioassays for all employees who were being monitored on in vivo or 

in vitro bioassay programs (WSRC, 1992). This would have explicitly included transient sCTWs 

on RWP-directed, job-specific bioassays, given the requirement to consider both routine and 

nonroutine bioassay programs. In the DuPont era, facility managers would have identified 

workers for termination bioassays, a process made difficult by the transient nature of some 

sCTWs, the roving nature of their work, and the lack of responsiveness by some workers to 

performing a termination bioassay before leaving the site. However, despite the addition of the 

1992 requirement, WSRC’s self-assessment in 1999 found that there continued to be a “Failure

to perform termination bioassays and, subsequently, failure to issue reports of terminated worker 

exposures” (WSRC, 1999b, p. 5). An adequate termination bioassay program was not realized 

until the 1999 response to this finding, which entailed the implementation of “new radiological 

compliance requirements so that adequate subcontractor tracking information is provided . . . The 

new requirements are more specific and detailed, and include possible future work restrictions 

for subcontract employees who fail to comply with radiological requirements at termination” 

(WSRC, 1999b, p. 5). The implications of not having an adequate termination bioassay program 

for subcontractors are clear: If internal monitoring was missed due to inadequate RWPs or 

incomplete job-specific bioassay submissions, any uptakes and potential internal dose would not 

have been necessarily caught at termination.

Facility source-term characterization. In 1999, WSRC prescribed a detailed facility sourceterm characterization methodology founded on a facility-by-facility baselining of relevant 

radiological source terms based on a review of “existing waste certification or process stream 

analysis data,” coupled with alternative means such as isotopic workplace air and contamination 

sampling (WSRC, 1999a, p. 2). Previous guidance, including various iterations of the 5Q1.1 

manual during the 1990s, had included earlier guidance that was founded on facility source terms 

identified from “contamination survey records, safety analysis reports (SARs), technical reports, 

the open literature, personal interviews, etc.” (WSRC, 1997, p. 3; similar statements in WSRC, 

1990b, 1992, 1993). 

The development of more objective, analysis-based guidance was prompted, in part, by a 1990 

finding by the DOE Tiger Team that WSRC’s internal dosimetry program did not comply with
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DOE Order 5480.11 because “Radiological areas have not been sufficiently characterized to 

provide a technical basis for the assignment of bioassay sample types and frequencies” (DOE, 

1990, p. 4-193). In response, WSRC noted that its approach was based on “years of experience 

[and an] awareness of what has constituted good practice in the past, common sense, and 

conservative assumptions for determining employee doses” (WSRC, 1990, PDF p. 432). 

Nonetheless, the WSRC corrective action plan called for “the radionuclide materials at each area 

on the site [to be] characterized” and for the development of the internal dosimetry technical 

basis manual (5Q1.1.) that was initially issued in 1992 (WSRC, 1990a, PDF p. 432). The in vitro 

bioassay types and frequencies table, themselves, remained essentially the same, as noted by 

NIOSH: “although the codes in the table were changed from those in DPSOL 193-211, the urine 

bioassay types were the same: plutonium, strontium, tritium, uranium, EU, and Am/Cm/Cf”

(NIOSH, 2019b, p. 19).

4

4 However, there was some attention paid to updating source terms and facility applications, as noted in RPRT0091: “The area names are not identical to the areas in the bioassay frequency table in DPSOL 193-211 but, where 

the areas can be matched together, there were changes in the routine bioassay types. Annual strontium sampling was 

added for 221-F Canyon, 221-F A-Line, and certain areas in Buildings 773-A, 772-F, and 241-84H” (NIOSH, 2019, 

pp. 19–20). 

Despite this additional guidance following the Tiger Team finding, the WSRC (1999a) guidance 

was found necessary “in response to a concern over prescribing the correct urine bioassay 

sampling program[s] on radiological work permits” (WSRC, 1998b, p. 1). For example, for 

Building 773-A (encompassing the Savannah River Technology Center), it was observed: 

Additionally, certain facilities such as the Savannah River Technology Center 

(SRTC) and the solid waste disposal facilities handle a wide array of radioactive 

materials, some of which may not be encountered in the typical radiological work 

environment by workers in those areas. For facilities such as 221-FB-Line, where 

the source term is well defined and not subject to change, this is not a concern 

unless there is a major change in the facility mission. To ensure that the proper 

radionuclide(s) is identified for the RWP urine sampling program it may be 

necessary to perform a thorough characterization of the work environment. It is 

important also that this characterization be performed on a routine basis to stay 

current on the source term present. [WSRC, 1998b, p. 2] 

As SC&A noted in its review of RPRT-0092, “such a routine, comprehensive characterization 

was not standardized practice during the DuPont era into the early WSRC era, except at specific 

facilities such as the Naval Fuel facility cited by DOE in its Tiger Team Assessment” (019a, 

p. 27).5

5 The Naval Fuel Facility did not fall under operational management by either DuPont or WSRC. It was managed 

as a tenant operation by the Naval Reactors division of DOE headquarters, with its own radiological control 

procedures and practices.

 The implications of not having complete or accurate radionuclides of concern SC&A, 

2listed on RWPs was recognized by both DOE and WSRC during the 1990s and was the subject 

of iterative changes to how SRS facility source terms were identified and characterized. For 

those nonroutine jobs that involved “non-routine mixes or concentrations” (Findley, 1997, 

PDF p. 9), appropriate job-specific bioassays would not have been specified by the RWPs in 

question if a line manager or RCO relied upon an outdated SAR or dated process knowledge that 
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did not reflect a new or evolving operation that would have introduced a new or unique 

radiological source term.

Later program developments. The formal issuance and required implementation of DOE’s 

10 CFR Part 835 regulation for occupational radiation protection in 1995–1996 had the effect of 

instilling enforceable accountability by all DOE contractors for monitoring of all potential 

radiation exposures of 100 millirem (mrem) or above. This was supplemented by administrative 

regulatory requirements governing nuclear safety program quality assurance that required 

managerial accountability for implementation of safety programs and procedures. There is no 

evidence that any further systemic program concerns were identified for SRS bioassay programs 

by internal or external oversight reviews following the 1998 Price-Anderson Amendments 

enforcement action.

The eventual implementation of and managerial accountability to the RIP upgrades to SRS 

radiological policies and procedures by the mid to late 1990s satisfied the bioassay program 

deficiencies identified by both external DOE and internal WSRC management. However, there 

was continued scrutiny of the SRS internal dosimetry program in the 1999–2007 period, which 

constitutes the balance of years in this SEC evaluation, and revisions were made. 

Within WSRC, the radiological program was regularly reviewed and updated. Notably, a 2005 

review of how radionuclides of interest were determined in the routine bioassay program 

determined that the “usefulness of waste characterization data, used extensively in the past to 

determine radionuclides of concern,” was becoming of more limited utility given then-ongoing 

efforts to consolidate and reduce waste streams at SRS (WSRC, 2005, p. 8). Therefore, more 

professional judgement by health physicists in the characterization process was stipulated. None 

of these procedural updates posed a deficiency or bioassay data gap for dose reconstruction 

feasibility under EEOICPA.6

6 However, findings and recommendations for co-exposure models, neptunium, and thorium remain for work 

group review and closure.

Similarly, as new issues arose, existing radiological monitoring requirements were reevaluated.

An example is the question of special tritium compounds (STCs), a DOE-wide issue that 

involved SRS in the early 2000s and led to the addition of specific DOE guidance on internal 

monitoring procedures. This issue is being addressed by the SRS work group as a separate SEC 

matrix issue.

4.2 Realization of improvements to radiological monitoring programs, 1991–

2007

As noted in section 3, newly issued or revised bioassay monitoring policies or procedures, and 

related programs, were not necessarily accepted and implemented fully by WSRC managers and 

workers in a timely manner. The embedded workplace safety culture, coupled with longstanding 

monitoring practices at SRS, would have made prompt sitewide changes in actual practice 

unlikely without accountability measures and effective self-assessments against accepted 

performance standards. This was acknowledged in The U.S. General Accounting Office’s 
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(GAO’s) 1990 review of that issue (related to SRS reactor restart; GAO, 1990) and reflected in 

the following onsite operating experience: 

• the internal site FEB determination in 1994–1995 of deficiencies in bioassay sample 

submissions for tritium, which “prompted the site to implement a bioassay sample 

tracking and delinquency program for tritium bioassay in May 1996” (WSRC, 1998c) 

• the WSRC self-assessment and DOE enforcement action in 1997–1998 surrounding 

non-submission of job-specific bioassays, which led to extensive procedural changes, 

including accountability and tracking measures (SC&A, 2019a)

• the FEB review and subsequent WSRC determination that concerns about 

nonrepresentative facility source-term characterization remained as late as 1998–1999, 

which led to use of a more comprehensive, analytic methodology (WSRC, 1999a) 

The implementation of an RWP program, while part of the corrective actions in response to the 

March 1990 Tiger Team assessment, was not implemented site wide until sometime in 1991–

1992, did not require bioassays for respirator use until 1992, did not specify all radionuclides of 

concern for job-specific bioassays until 1994, and was not supported by comprehensive, 

analysis-based source term characterization until 1999. While Manual 5Q1.1 requirements for 

these provisions were successively issued and updated beginning in 1992, administrative 

accountability and tracking measures to ensure that workers not covered by the routine bioassay 

program submitted the required job-specific bioassay samples subsequently were found to be 

ineffective (WSRC, 1998c). 

Despite a Tiger Team finding on non-submission of bioassay samples in 1990, corrective actions 

to ensure adherence to job-specific bioassay requirements were only taken following a 

succession of noncompliance findings. These included a 1995 DOE (Savannah River Operations 

Office) oversight finding, a subsequent 1997 WSRC self-assessment to ascertain whether those 

workers required to provide job-specific bioassays actually did so, and a 1998 DOE enforcement 

action and WSRC corrective action program (DOE, 1998; WSRC, 1998d). As noted by WSRC, 

while the “expected percent participation implied by 10CFR835 and WSRC 5Q Manual is 

100%,” it was found that only 21 percent of sitewide workers provided the required job-specific 

bioassays in the second quarter of 1997 (WSRC, 1998d, p. 2). As indicated by SC&A in its 

various reviews of the SRS ER, the WSRC survey of job-specific bioassay completeness was 

limited to 1997, but the independent DOE oversight reviews of 1990 and 1995, coupled with the 

FEB findings in 1994–1995 (for non-submission of tritium bioassay samples), indicated that the 

problem persisted throughout the early 1990s under WSRC until 1998 when the bioassay 

collection and assurance system was overhauled.

The root problems underlying these persistent institutional deficiencies for job-specific bioassays 

were found by WSRC to include the following (summarized from WSRC 1998d): 

• Workers did not realize that they needed a job-specific bioassay. “Many of the 

workers that missed job-specific samples were on a routine sample program but not for 

the isotopes for that specific job” (WSRC, 1998d, p. 3). 
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• The worker was transferred before completion of the job. “A worker may sign-out on 

an RWP, believing that he will be back in the near future. However, because of 

reassignment or other reasons, he may never return to the job” (WSRC, 1998d, p. 4). The 

worker may then forget or fail to submit the sample called for. 

• Workers thought they were on the correct routine bioassay program because their

radiological qualifications badge (RQB) indicated the correct isotopes. WSRC found 

that notations on the RQB sometimes did not match the database that generated sample 

requests, leading to non-submissions. 

• Bioassay requirements were not presented clearly and consistently in SRWPs and 

RWPs: “the instructions in some of the SRWPs for bioassay samples were not clear. The 

requirements in RWPs were not presented in a consistent manner” (WSRC, 1998d, p. 4).

• Job-specific bioassay requirements were not always adequately emphasized in the 

pre-job briefings, and the workers needing job-specific samples were not always 

identified and documented. 

Based on the significance and scope of these corrective actions, WSRC concluded in its 1998 

corrective action report (WSRC, 1998d, p. 2) that: 

While it was not the function of this root cause analysis team to investigate the 

failure of earlier corrective actions made between March and July 1996 to the jobspecific bioassay program, it was apparent that management oversight, through 

self-assessments and audits, to determine the effectiveness of the corrective 

actions was lacking. (Note: The 1996 corrective actions defined the current 

program). Therefore, as an additional corrective action, the self-assessment 

program will be modified to include an assessment of the effectiveness of the 

corrective actions implemented as a result of the root cause analysis. [Emphasis 

added.] 

Following issuance of this WSRC corrective action report and coupled with actions taken in 

response to the DOE enforcement action, additional sitewide self-assessments were conducted 

during 1998, including a detailed examination of SRWPs requiring bioassay sampling. That 

followup review found multiple deficiencies in how permits prescribed bioassay sampling for 

radionuclides other than tritium. These included (WSRC, 1998d): 

• Use of outdated permit forms that did not include a bioassay requirement block and no 

means to indicate which radionuclides are of concern other than reference to a procedure 

for facility-specific routine bioassays. As emphasized by WSRC’s review of these 

outdated forms, “it does not and cannot indicate the required radionuclide for a jobspecific bioassay sample as this is dependent on the job being performed” (p. 2; 

emphasis added).

• “It is not possible to tell by document review whether a worker meets this requirement 

[special precautions block indicated a bioassay code for neptunium bioassay] since there 
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is no indication on the sign-in sheet as to which facility was entered” (p. 3; emphasis 

added). 

• “There is no consistency amongst facilities when indicating bioassay sampling related 

information in the special precautions section of the SRWP” (p. 4). For example, “A jobspecific bioassay sample must be submitted by workers not participating in a 

routine bioassay program for radionuclide(s) specified in the Bioassay 

Requirements section (and nothing else)” (p. 4), meaning that while the admonition is 

included, no job-specific target radionuclides are specified on the permit.

• “Some facilities require bioassay sampling only when respiratory protection is worn and 

others require bioassay sampling when there is no requirement for respiratory protection. 

. . . It was determined during previous document reviews of SRWP sign-ins that it is 

impossible to identify which workers should have left a bioassay sample and which 

did not have to in these cases because it is not apparent who wore a mask” (p. 4; 

emphasis added).

• “Some facilities are not performing airborne radioactivity monitoring or setting 

suspension limits for radionuclides identified as requiring bioassay sampling” (p. 4).

As noted in WSRC’s November 2, 1999, “Response to the Compilation of PAAA Internal 

Dosimetry Issues,”7

 the problem with bioassay samples not being collected and processed was 

“resolved initially by an elaborate administrative monitoring program to ensure job-specific 

sampling compliance” (WSRC, 1999b, p. 6), but WSRC determined that the final solution was 

the implementation of a new bioassay routine program on March 1, 1999, that “did away with 

the job-specific program for non-tritium samples entirely” (WSRC, 1999b, p. 6). Regarding 

subcontractor non-submission of bioassay samples, the same WSRC response notes that 

“Subcontractor workers are now being tracked administratively and can be kept from performing 

future site radiological work if they fail to comply with radiological requirements, including 

failure to provide a termination bioassay sample” (WSRC, 1999b, p. 2).

7 This WSRC Health Physics Technology Internal Dosimetry division reviewed a list of 31 general deficiencies 

provided by DOE’s Office of Enforcement and Investigation as part of a 120-day suspension of enforcement actions

for issues associated with DOE-wide contractor internal dosimetry evaluation programs. WSRC conducted an indepth self-appraisal against these identified deficiencies, determined which applied to SRS, and developed 

corresponding corrective actions. The “Response to the Compilation of PAAA Internal Dosimetry Issues” (WSRC, 

1999b) is a record of that review and actions taken.

This same compilation of actions acknowledged that workers may have been enrolled in 

incorrect routine bioassay programs due to incorrect facility source terms being designated on 

RWPs. It noted that “radiological hazards are now more formally documented and both a 

periodic review and a method for re-evaluation [are] defined” (WSRC, 1999b, p. 6). In terms of 

follow up, it noted that an RCO self-assessment completed on April 30, 1999, “determined that 

formally documented source terms are [now] being properly used to designate bioassay 

requirements on RWPs” (WSRC, 1999b, p. 6).
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4.3 Timetable of WSRC procedural upgrades and implementation, 1991–2007

Table 1 provides a chronology of changes to policies and procedures governing SRS bioassay 

monitoring in the 1989–1999 period, coupled with available assessments of program 

implementation and manifest bioassay data availability and completeness. This is based on the 

preceding history of WSRC and DOE actions in the 1990s and SC&A’s and NIOSH’s various 

assessments of bioassay data completeness for nonroutine, job-specific bioassays. 

Table 1. Chronology of changes to policies and procedures and RWP bioassay data 

evaluation

Year

RPRT-0092 RWP bioassay data 

characterization * Programmatic

1989 No RWPs available for analysis • April 1: WSRC assumes SRS operations

contract. 

1990 Only 1 RWP available for analysis with 

no bioassay requirements or bioassay 

located for single worker involved 

• June 1: DOE Tiger Team compliance 

assessment. 

• September: WSRC corrective action plan 

(for Tiger Team findings). 

1991 RWP specifies bioassay: 3%

Direct monitoring: 72%

Effective monitoring: 88%

NA

1992 RWP specifies bioassay: 0%

Direct monitoring: 91%

Effective monitoring: 96%

• Manual 5Q1.1, procedure 506 (rev. 0):

updated procedures for bioassay monitoring; 

JSB required w/ respirators. 

1993 RWP specifies bioassay: 3%

Direct monitoring: 70%

Effective monitoring: 83%

NA

1994 RWP specifies bioassay: 63%

Direct monitoring: 73%

Effective monitoring: 90%

• Target radionuclides listed on RWPs.

• July: SRS Facility Evaluation Board:

inadequate submission of tritium bioassays. 

1995 RWP specifies bioassay: 85%

Direct monitoring: 68%

Effective monitoring: 83%

• February & March: SRS Facility Evaluation 

Board: Inadequacies in specifying bioassay 

sampling requirements on RWPs. 

• DOE-SR oversight: inadequate submission 

of JSB. 

1996 RWP specifies bioassay: 85%

Direct monitoring: 75%

Effective monitoring: 83%

• May: WSRC initiates sample tracking, 

delinquency followup for tritium bioassays. 
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Year

RPRT-0092 RWP bioassay data 

characterization * Programmatic

1997 RWP specifies bioassay: 94%

Direct monitoring: 95%

Effective monitoring: 98%

• WSRC self-assessment: 79% Q2 JSB not 

submitted. 

• 100% resampling of missing JSB show no 

detectable intakes. 

• December: Corrective action report issued 

for JSB program deficiencies. 

1998 RWP specifies bioassay: 72%

Direct monitoring: 80%

Effective monitoring: 96%

• January: WSRC corrective plan w/ 11 

actions to upgrade JSB program; actions 

completed by March 30, 1998. 

• August: 5Q1.1 (504) link between routine 

sampling scheduling and frequency, and 

RWP program eliminated – not appropriate. 

• SRS Facility Evaluation Board: source-term 

characterization in support of RWPs 

inadequate. 

• September: DOE/HQ enforcement action for 

inadequate submission of JSB. 

1999 Outside scope of RPRT-0092 

evaluation

• March: WSRC implements new routine 

bioassay program; no JSB for non-tritium 

samples. WSRC responses and corrective 

actions to SRS independent self-assessment 

of internal dosimetry program (including 

accountable termination program for subs).

• New facility source term characterization 

methodology for RWPs implemented. 

* Monitoring percentages reflect SC&A analysis considering all assumed or required radionuclides for 

RWP. 

As the timeline in table 1 illustrates, WSRC developed a corrective action plan in response to the 

DOE Tiger Team assessment in September 1990 and conducted its own reviews, which led to the 

development of the RIP by late 1990. That plan included the issuance of what became the 5Q1.1 

manual for internal dosimetry, which defined updated procedures for RWPs, source-term 

characterization, and termination bioassays, among other monitoring requirements. The initial 

version of 5Q1.1 was issued in 1992, followed by successive revisions, which included target 

radionuclides on RWPs in 1994 and additional guidance on when and how to use job-specific 

bioassays. These changes are manifest by the inclusion of specific radionuclide source terms on 

RWPs reviewed by SC&A in the 1994–1995 timeframe (refer to figure 1 and table 2). However, 

the problem of non-submission of bioassays identified by DOE in the 1990 Tiger Team 

assessment persisted at SRS, as determined by internal FEB findings for incomplete tritium 

bioassay submissions in 1994–1995 and for non-tritium bioassays in DOE’s oversight findings in 

1995 and WSRC’s self-assessment in 1997. 

Likewise, while WSRC committed to addressing DOE’s finding of deficient facility source-term 

characterization to support RWPs, it was not until internal FEB findings in 1998 of continuing 
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reliance on longstanding and outdated SRS practices (reliance on SARs, facility experience, and 

expertise, etc.) that WSRC took concerted action to move to a sitewide comprehensive, analysisbased approach in 1999 to ensure that appropriate radionuclide source terms were reflected on 

RWPs and SRWPs according to operational presence and exposure potential. 

For the time period 1999–2007, following WSRC’s action to revise the sitewide in vitro internal 

bioassay monitoring (effective March 1, 1999) and revise specification of urine bioassay 

requirements on RFWPs (March 10, 1999), several SRS internal dosimetry issues arose, as 

discussed in the next two paragraphs. 

Special tritium compounds (STCs) (also termed stable metal tritides) became a DOE-wide 

concern in the early 2000s and were recognized as an SRS concern as early as 2002, when 

WSRC initiated a sitewide survey of STCs, described existing sources at SRS, and outlined what 

radiological controls and monitoring would be required (WSRC, 2002). In particular, it became 

understood that routine bioassay monitoring may not detect the more insoluble STCs at the 

100-mrem threshold defined in 10 CFR Part 835. This potential SEC issue was identified for 

SEC-00103 and addressed in NIOSH’s ORAUT-RPRT-0072, revision 00, “Locations of Stable 

Metal Tritide Use at the Savannah River Site” (NIOSH, 2017a). While there were potential 

monitoring lapses before 2004, the use of personal air samplers with special filters and more 

specific identification of STCs and their solubilities for bioassay purposes resolved the concern 

going forward (Findley, 2010). As noted in SC&A’s October 25, 2021, informal internal 

memorandum to the SRS and SEC Issues work groups, NIOSH and SC&A resolved all 

comments and responses, and the concern awaits work group action (SC&A, 2021). 

An assessment of the Savannah River National Laboratory by the FEB in 2004 revisited the 1998 

conclusion that waste characterization data ought to be the key means to determine the facility 

RWP bioassay requirements (WSRC, 2005). It was concluded that “the usefulness of waste 

characterization data, used extensively in the past to determine radionuclides of concern, is 

becoming more limited as Facilities consolidate and reduce the number of waste streams” 

(WSRC, 2005, p. 8). WSRC observed that “it is not necessary to perform an a priori 

determination of the radionuclides of interest for every task and worker within a Facility,” and 

that an approach may be warranted making “use of PAS [personal air samplers], along with some 

prudent assumptions, [to allow] the task to be performed with no increased risk to the worker” 

(WSRC, 2005, p. 8). Finally, the assessment identified a need for the “radionuclides of concern 

[to be] determined . . . whenever possible, through the isotopic analysis of air samples within the 

facility” (p. 8). This program review indicates the attention that WSRC was giving, in this latter 

period, to operational changes at the site and the importance of keeping source term 

characterization in support of RWPs up to date. 
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5 Review of Subcontractor Job-Specific Bioassay Completeness and 

Representativeness, 1991–1998

5.1 Analysis of when RWPs specified radionuclides to be bioassayed

Although corporate and policy changes were initiated in 1990, those changes did not take place 

immediately. It took well into the 1990s to implement changes in the field and to obtain better 

bioassay participation and record storage and retrieval. Some of the relevant issues and 

deficiencies that extended into the 1990s have been previously discussed by the SRS and SEC 

Issues work groups while evaluating the 1972–1990 data. If the necessary changes had been 

implemented relatively quickly, then there would not have been issues that were being identified 

and addressed in the 1990s. Examples of issues that extended into the 1990s are described in the 

DOE 1998 occurrence report, “Inadequate Participation in the Job-Specific Bioassay Program” 

(DOE, 1998b); the 1998 “Root Cause Analysis for Corrective Action Report #97-CAR-07-0001” 

(WSRC, 1998d); and the 1999 WSRC interoffice memorandum, “Response to the Compilation 

of PAAA Internal Dosimetry Issues” (WSRC, 1999b). 

SC&A analyzed the data in table C-1 of RPRT-0092 to determine when RWPs began to state if a 

bioassay was necessary, and the types of radionuclides that should be bioassayed. SC&A sorted 

the data in table C-1 according to the year of the RWP (1991–1998) and determined the total 

number of radionuclide bioassays mandated by adding the number of bioassays specifically 

required by an RWP (represented by the symbol “R” in table C-1) plus the number assumed to 

be needed by NIOSH (represented by the symbol “A” in table C-1). The number (R) of bioassays 

specifically stated on the RWP was then divided by the total number (R + A) of mandated 

bioassays to obtain the fraction of bioassays mandated in RPRP-0092 that were specifically 

required on the RWPs. The results for 1991–1998 are shown in figure 1. 
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Figure 1. Fraction of total mandated bioassays that were listed on the RWP versus year

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

0.80

0.90

1.00

1991 1992 1993 1994 1995 1996 1997 1998

The analysis was performed for each of the major radionuclides commonly bioassayed for at 

SRS for the years 1991–1998. The results are summarized in table 2. 
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Table 2. Percent of RWP-specified radionuclide bioassays compared to total number of mandated radionuclide bioassays 

as listed in RPRT-0092, table C-1 

Year

Percent 

of Pu 

bios 

required 

by RWPs

Total of 

RWP plus 

assumed 

Pu bios

Percent 

of Sr/FPs 

bios 

required 

by RWPs

Total of 

RWP plus 

assumed 

Sr/FPs 

bios

Percent 

of Am 

bios 

required 

by RWPs

Total of 

RWP plus 

assumed 

Am bios

Percent 

of U bios 

required 

by RWPs

Total of 

RWP plus 

assumed 

U bios

Percent 

of Np 

bios 

required 

by RWPs

Total of 

RWP plus 

assumed 

Np bios

1991 0% 16 0% 13 0% 4 25% 4 0% 1

1992 0% 23 0% 9 0% 12 0% 20 0% 2

1993 4% 27 0% 12 0% 13 9% 11 0% 11

1994 78% 32 72% 25 33% 9 33% 15 NA 0

1995 100% 15 100% 5 0% 2 100% 2 33% 3

1996 100% 7 100% 3 0% 2 NA 0 100% 1

1997 100% 9 100% 8 0% 1 NA 0 NA 0

1998 80% 10 71% 7 0% 1 NA 0 NA 0

Note: bios = bioassays; Pu = plutonium; Sr/FPs = strontium/fission products; Am = americium; U = uranium; Np = neptunium; NA = not applicable.
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The results in figure 1 and table 2 indicate that RWPs began to specify that a bioassay was 

required for certain radionuclides in the mid-1990s (1994 to 1995). 

5.2 Requiring only at least one bioassay versus requiring all mandated 

bioassays

When SC&A compared data in RPRT-0092, table 4-1 (sCTWs with at least one bioassay for any 

radionuclide, 1990–1998), to data obtained when considering all mandated radionuclides for an 

RWP (with a 2-year time limit on chest counts), it was found that the results adjust downward to 

lower percentages. For the period 1991–1998 for table 4-1 and table 6-4 (rates of monitoring 

sCTWs for at least one radionuclide, 1981–1988), the average percentage with at least one 

bioassay directly monitored to satisfy an RWP was 96 percent, while SC&A’s recalculated 

average percentage with bioassays for all mandated radionuclides directly monitored as specified 

for an RWP was 77 percent. The values from table 4-1 and table 6-4 of the average percentage of 

sCTWs effectively monitored for at least one bioassay for an RWP was 98 percent, while 

SC&A’s recalculated average percentage effectively monitored for all mandated radionuclides to 

satisfy an RWP was 89 percent. Table 3 summarizes the results of NIOSH’s analysis in RPRT0092 and SC&A’s analysis for direct monitoring; table 4 summarizes effective monitoring, 

which included bioassays for plutonium (Pu), strontium/fission products (Sr/FPs), uranium (U), 

americium (Am), and neptunium (Np), as mandated for an RWP, for 1991–1998. 

Table 3. Breakdown by year of using all mandated radionuclides and using only at least 

one radionuclide for sCTWs directly monitored 1991–1998

Year

Total number of sCTWRWP matches requiring 

bioassays

SC&A percent directly 

monitored for all 

mandated radionuclides

RPRT-0092 table 4-1 

percent directly 

monitored for at least 

one radionuclide

1991 81 72% 99%

1992 106 91% 97%

1993 173 70% 97%

1994 140 73% 94%

1995 57 68% 95%

1996 24 75% 83%

1997 55 95% 98%

1998 25 80% 92%

1991–1994 500 75% 97%

1995–1998 161 80% 94%

All years 661 77% 96%
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Table 4. Breakdown by year of using all mandated radionuclides and using only at least 

radionuclide for sCTWs effectively monitored 1991–1998

Year

Total number of sCTW 

matches requiring 

bioassays

SC&A percent 

effectively monitored 

for all mandated 

radionuclides

RPRT-0092 table 4-1 

percent effectively 

monitored for at least 

one radionuclide

1991 81 88% 100%

1992 106 96% 100%

1993 173 83% 99%

1994 140 90% 96%

1995 57 83% 100%

1996 24 83% 83%

1997 55 98% 100%

1998 25 96% 100%

1991–1994 500 89% 98%

1995–1998 161 90% 98%

All years 661 89% 98%

The results of using NIOSH’s criteria that only one bioassay needed to be monitored to fulfill the 

RWP monitoring requirements as opposed to requiring that all mandated radionuclides for an 

RWP be monitored to fulfill RWP requirements are sometimes misleading because they do not 

incorporate the need for the sCTW, or the co-exposure worker, to be monitored for all mandated 

radionuclides, with the chest count limited to 2 years. The details of this issue were presented in 

section 6.2.2 of SC&A’s 2019 review of RPRT-0092 (SC&A, 2019a). Additionally, the merits of 

using co-exposure data to add to the percentage of sCTW monitored is debatable; this issue was 

presented in section 6.3 of SC&A’s 2019 review of RPRT-0092 (SC&A, 2019a). 

5.3 RPRT-0092 data versus 1997 SRS self-assessment

A more significant issue is that the data used in RPRT-0092 appear to have failed to identify the 

missed job-specific bioassays as outlined in figure 4-4, page 39, of RPRT-0092 (NIOSH, 2019a; 

reproduced here as figure 2), which was taken from WSRC (1998d). The flowchart is the 

expected process; the large numbers represent actual first four months of 1997 participation as 

analyzed in May 1997 (NIOSH, 2019a, p. 38).
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Figure 2. Figure 4-4 from RPRT-0092: attachment 2 to root cause analysis corrective 

action report

Source: NIOSH (2019a), figure 4-4, “Attachment 2 to Root Cause Analysis Corrective Action Report ([WSRC, 1998d], 

p. 23). The flowchart is the expected process; the large numbers represent actual May 1997 participation.”

SC&A analyzed the data in RPRT-0092 to determine the percentage of sCTWs bioassayed for 

the total number of mandated bioassays (R + A) for an RWP when all mandated radionuclides 

are needed for the sCTW to be considered monitored. The results for both directly and 

effectively monitored sCTWs are shown in figure 3. The percent values are similar to those in 

tables 10 and 12 of SC&A’s RPRT-0092 review (SC&A, 2019a). 
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Figure 3. Percent of directly and effectively monitored sCTWs per RWP-mandated 

bioassays (R + A)

However, the mostly routine bioassay data tend to overshadow the missed sCTW job-specific 

bioassays, such as those in the set of 107 missed bioassays during the first four months of 1997, 

as referred to in figure 4-4 and page 38 of RPRT-0092. The much lower number of job-specific 

bioassays would not have the potential to provide a significant impact on the overall percent 

monitored.

5.4 Analysis of compliance as a function of building for 1991–1998

SC&A analyzed compliance of mandated bioassays for sCTWs as a function of the buildings 

specified on RWPs for the period 1991–1998 to determine if there appeared to be an inflection 

point that might demonstrate an increase in bioassay compliance. SC&A performed this analysis 

on an annual basis for each of the five major radionuclides bioassayed for at SRS—plutonium, 

uranium, strontium/fission products, americium, and neptunium—for all buildings listed on 

RWPs for the period 1991–1998, for both direct monitoring and effective monitoring. Tables 5–9 

summarize the results for directly monitored sCTWs. Results with less than 80 percent 

compliance are indicated in tables 5–9 by a table note and bold italic formatting. SC&A’s 

selection of the compliance value less of than 80 percent was arbitrary, but it was a reasonable 

value below which the rate of compliance certainly would be questionable. 
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Table 5. Percent of directly bioassayed sCTWs working on RWPs for plutonium versus 

area and year

Area and 

building 

Total 

number of 

Pu 

mandated 

bioassays a

1991 1992 1993 1994 1995 1996 1997 1998

A-773 112 89% 100% 86% 100% NA NA NA NA

E-230 4 NA NA NA 100% NA NA NA NA

E-643 19 NA NA 100% 40% b NA NA 100% NA

F-211 1 NA NA NA NA NA NA NA 100%

F-221 33 NA 100% NA NA 60% b NA 100% 56% b

F-235 24 100% NA 73% b NA 100% NA NA NA

F-241 75 78% b NA 80% NA NA 100% 97% 89%

F-247 11 100% NA 78% b NA NA NA NA NA

F-281 3 NA NA NA 100% NA NA NA NA

F-292 5 NA NA NA NA 100% NA NA NA

F-294 6 NA NA NA NA 83% NA NA NA

F-772 23 NA 100% NA 55% b NA NA NA NA

F-FA-Line 2 NA NA NA NA 100% NA NA NA

F-FB-Line 11 100% 100% NA NA NA NA 100% 100%

F-FTF 1 NA NA NA NA NA NA NA 100%

H-0BL 65 NA 100% 94% NA NA NA NA NA

H-211 4 NA 100% NA NA NA NA NA 100%

H-221 75 NA 93% 92% 100% 93% 60% b NA NA

H-241 42 96% 89% NA NA NA NA NA NA

H-242 14 100% NA NA NA NA NA NA NA

H-261 2 NA NA NA NA NA NA 100% NA

H-281 2 NA NA NA 100% NA NA NA NA

H-292 11 NA 100% NA NA NA NA NA NA

H-299 9 100% NA NA NA NA NA NA NA

H-HBL 2 NA NA NA NA 50% b NA NA NA

H-HCMA 4 NA NA 100% NA NA NA NA NA

Outside 4 NA NA 75% b NA NA NA NA NA

Z-210 5 NA NA NA 40% b NA NA NA NA

Z-451 59 NA NA NA 61% b NA NA NA NA

Z-704 15 NA NA NA 60% b NA NA NA NA

a Total number of mandated bioassays are those specified on RWP plus assumed bioassays for the RWP.

b Results with <80% compliance.

Note: NA = No RWPs for that year for that building. Percentage values are percent of sCTWs directly bioassayed as 

mandated for RWPs, with chest counts within 2 years.
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Table 6. Percent of directly bioassayed sCTWs on RWPs for strontium/fission products 

versus area and year

Area and 

building 

Total 

number of 

Sr/FPs 

mandated 

bioassays

1991 1992 1993 1994 1995 1996 1997 1998

A 773 112 100% 100% 100% 100% NA NA NA NA

E 230 4 NA NA NA 100% NA NA NA NA

E 643 19 NA NA 100% 60% a NA NA 100% NA

F 221 24 NA NA NA NA 80% NA 100% 78% a

F 241 76 100% NA 100% NA NA 86% 92% 100%

F 247 4 100% NA 100% NA NA NA NA NA

F 281 3 NA NA NA 100% NA NA NA NA

F 292 5 NA NA NA NA 100% NA NA NA

F 294 6 NA NA NA NA 100% NA NA NA

F 772 16 NA 92% NA 100% NA NA NA NA

F FA-Line 2 NA NA NA NA 100% NA NA NA

F FTF 1 NA NA NA NA NA NA NA 100%

F outside 4 NA NA 100% NA NA NA NA NA

H 211 1 NA NA NA NA NA NA NA 100%

H 221 4 NA NA NA NA 100% NA NA NA

H 241 42 96% 95% NA NA NA NA NA NA

H 242 9 100% NA NA NA NA NA NA NA

H 261 2 NA NA NA NA NA NA 100% NA

H 299 9 100% NA NA NA NA NA NA NA

H HCMA 4 NA NA 100% NA NA NA NA NA

Z 210 5 NA NA NA 100% NA NA NA NA

Z 451 59 NA NA NA 100% NA NA NA NA

Z 704 15 NA NA NA 100% NA NA NA NA

a Results with <80% compliance.
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Table 7. Percent of directly bioassayed sCTWs working on RWPs for uranium versus 

area and year

Area and 

building 

Total 

number of 

U 

mandated 

bioassays

1991 1992 1993 1994 1995 1996 1997 1998

A-773 98 50% a 100% 82% 95% NA NA NA NA

F-221 6 NA 83% NA NA NA NA NA NA

F-247 11 50% a NA 89% NA NA NA NA NA

F-281 3 NA NA NA 100% NA NA NA NA

F-772 16 NA 100% NA 100% NA NA NA NA

H-211 3 NA 100% NA NA NA NA NA NA

H-221 45 NA 93% 83% 90% 100% NA NA NA

H-281 2 NA NA NA 100% NA NA NA NA

H-299 9 56% a NA NA NA NA NA NA NA

H-HCMA 4 NA NA 100% NA NA NA NA NA

H-OBL 9 NA 100% NA NA NA NA NA NA

M-313 3 NA 100% NA NA NA NA NA NA

M-316 2 NA 100% NA NA NA NA NA NA

M-321 13 NA 92% NA NA NA NA NA NA

a Results with <80% compliance. 

Table 8. Percent of directly bioassayed sCTWs working on RWPs for americium versus 

area and year

Area and 

building 

Total 

number of 

Am

mandated 

bioassays

1991 1992 1993 1994 1995 1996 1997 1998

A-773 13 NA NA NA 92% NA NA NA NA

F-247 7 0% a NA 20% a NA NA NA NA NA

F-772 4 NA 100% NA NA NA NA NA NA

H-211 4 NA 100% NA NA NA NA NA 100%

H-221 49 NA 73% a 67% a 90% 33% a 100% NA NA

H-242 9 22% a NA NA NA NA NA NA NA

H-261 2 NA NA NA NA NA NA 100% NA

H-281 2 NA NA NA 100% NA NA NA NA

H-292 11 NA 100% NA NA NA NA NA NA

H-299 9 44% a NA NA NA NA NA NA NA

H-HCMA 4 NA NA 50% a NA NA NA NA NA

H-OBL 65 NA 92% 65% a NA NA NA NA NA

a Results with <80% compliance. 
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Table 9. Percent of directly bioassayed sCTWs working on RWPs for neptunium versus 

area and year

Area and 

building 

Total 

number of 

Np 

mandated 

bioassays

1991 1992 1993 1994 1995 1996 1997 1998

F-235 20 50% a NA 45% a NA 33% a NA NA NA

H-HBL 2 NA NA NA NA 0% a NA NA NA

H-OBL 65 NA 100% 71% a NA NA NA NA NA

a Results with <80% compliance. 

The percentage values in tables 5–9 do not indicate an obvious change in bioassay compliance 

during the period 1991–1998 for the five radionuclides. However, for some of the radionuclides 

there was an insufficient number of RWPs during the 1995–1998 period to provide statistically 

significant results.

However, table 8 and table 9 do indicate significant noncompliance issues for americium and 

neptunium for the period 1991–1995. The same analysis method was conducted for effectively 

monitored sCTW on RWPs for the period 1991–1998 with similar results as for directly 

monitored sCTWs, with an equal or greater percentage of sCTW effectively monitored because 

co-exposure bioassays were also included. 

5.5 Analysis of noncompliance for 1991–1998

SC&A further analyzed the results in terms of noncompliance as a function of radionuclide and 

year. For the purpose of this exercise, SC&A selected <80 percent as an arbitrary threshold for 

direct bioassay monitoring for an area or building, below which compliance would certainly be 

questionable. SC&A divided the results into two periods, 1991–1994 and 1995–1998, to see if 

there was any obvious step function that would indicate a greater compliance rate after 1994 

when RWPs began to be more prescriptive. However, there does not appear to be a defining 

inflection point. Figures 4 and 5 summarized the results for sCTWs directly monitored. In these 

two figures, a high fraction of missed bioassay results means poor compliance. The results were 

mixed. For example, bioassay noncompliance was greater for plutonium, uranium, and 

americium for 1991–1994 (taller hashed bars) compared to 1995–1998 (shorter black bars) as 

shown in figure 4, but Sr/FPs and neptunium bioassay noncompliance was greater for 1995–1998 

(taller black bars) compared to 1991–1994 (lower hashed bars) as shown in figure 5. However, 

there were only three RWPs with 11 workers for 1995 for neptunium. Americium and neptunium 

had a greater amount of noncompliance (ranging from 20 to 100 precent) compared to 

plutonium, Sr/FPs, and uranium (noncompliance ranged from zero to 24 precent), perhaps 

because plutonium, Sr/FPs, and uranium were more likely to be covered by routine bioassays 

whereas americium and neptunium radionuclides were not as common (and more likely to be on 

job-specific bioassays). As mentioned previously, for some radionuclides there was an 

insufficient number of RWPs in the 1995–1998 period to provide statistically significant results. 
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Figure 4. Directly bioassayed radionuclides with 1991–1994 noncompliance fraction 

greater than 1995–1998 noncompliance fraction

0.000

0.100

0.200

0.300

0.400

0.500

0.600

0.700

0.800

0.900

1.000

Pu U Am

Fraction

1991-1994 1995-1998

Figure 5. Directly bioassayed radionuclides with 1991–1994 noncompliance fraction 

less than 1995–1998 noncompliance fraction

The same analysis method was conducted for effectively monitored sCTWs on RWPs for the 

period 1991–1998, with similar results as for directly monitored sCTWs, with equal or less 

noncompliance values for sCTW bioassays because co-exposure bioassays were also included. 
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6 Review and Overview of SEC-Related Issues, 1972–2007

On behalf of the SRS work group, SC&A has maintained an updated SEC issues matrix, starting 

in September 2009, that compiles all identified exposure potential issues at SRS based on the 

work group’s review of petition SEC-00103. The original 2009 matrix (SC&A, 2009) was based 

on issues that were unresolved from the SC&A review of the SRS site profile and SC&A’s 

preliminary review of NIOSH’s ER (NIOSH, 2008). The 2009 matrix listed 25 issues of SEC 

relevance. 

Until 2022, the most recent update to the SEC issues matrix was issued in February 2014 

(SC&A, 2014a) following the designation of an SEC class for all SRS employees for 1953–1972. 

This designation rendered moot some SEC issues, while others needed additional research to 

address questions related to latter time periods, including those for CTWs, nuclide-specific issues 

(e.g., neptunium, special tritium compounds, and thorium), and co-exposure modeling. For this 

current review, SC&A reviewed the 2014 matrix to confirm any outstanding issues for which 

documented resolution is not apparent. 

Of the 26 SEC-relevant issues listed in the 2014 matrix, three issues lacked a documented 

resolution: issue 3 for “Recycled Uranium,” issue 22 for “Badges not capturing dose,” and 

issue 26 for “additional worker and worker representative issues.” 

The original recycled uranium (RU) issue, which was identified in SC&A’s 2005 site profile 

review (SC&A, 2005), found that a timeline for RU operations had not been issued and it was 

not clear when and how RU (with trace radiological contaminants) may have been handled at 

SRS. NIOSH issued trace contaminant data for RU in 2010 (NIOSH, 2010), and SC&A 

responded with a memorandum about remaining RU issues in 2014 (SC&A, 2014b). While there 

is no confirmation of an outstanding SEC issue, no final resolution was apparent in the work 

group records on this matter. 

For issue 22 (and subsumed issue 23), SC&A had found that worker interviews indicated that 

some workers kept their badges out of higher radiation areas in order to not exceed dose limits 

(SC&A, 2011) and that badge dose reading may have been under-recorded or not recorded. 

NIOSH was to review SC&A’s report of these worker interviews and provide a response.

For issue 26, SC&A had compiled and categorized a number of worker and petitioner comments 

about specific workplace issues for which a specific NIOSH response has not been received to 

date. However, as noted in SC&A’s recently updated matrix (SC&A, 2022), a number of the 

comments are addressed in existing SEC issues reviewed by the work group and NIOSH. 

A number of other SEC-relevant issues from the 2014 matrix have either been closed, resolved, 

subsumed under other issues, or superseded by the 2011 Board action to recommend an SEC for 

1953–1972 (issues 1, 8, 12, 15, 16, 17, 18, 19, 21, 23, 24, and 25). Still others are being 

addressed by the development of co-exposure models under ORAUT-OTIB-0081, “Internal 

Dosimetry Co-Exposure Data for the Savannah River Site”: issue 2 for thorium via ORAUTRPRT-0070 (NIOSH, 2017c) and ORAUT-RPRT-0081 (NIOSH, 2017d); issue 4 for trivalent 

actinides and thorium; issues 6 and 7 for fission and activation products; issue 9 for tritium; and 

issue 13 for comparing intakes for construction workers versus non-construction workers. Issue 5 
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for Np-237 has been addressed by NIOSH in ORAUT-RPRT-0065 (NIOSH, 2016a), ORAUTRPRT-0077 (NIOSH, 2016b), and ORAUT-RPRT-0080 (NIOSH, 2017b) and is being handled 

by the work group as an ongoing issue. Issue 10 for special tritium compounds, which are being 

addressed as “Metal Hydrides” in ORAUT-RPRT-0072 (NIOSH, 2017a), is also ongoing. 

Issue 11 (exotic radionuclides), issue 14 (special exposure conditions), and issue 20 (tank farm 

geometry) have reached the resolution stage and are ready for work group review for closure. 

Other than the three specific outstanding items—issues 3, 22, and 26, none of which have been 

judged SEC significant to date—SC&A has determined that the relevant SEC issues have flowed 

down to and have been included in subsequent priority action lists presented by NIOSH to the 

work group. Their status is summarized in SC&A’s informal internal update of SEC-00103 

issues status in October 2021 (SC&A, 2021). 

Given how long ago this 2014 issues matrix was last updated and the challenge faced by SC&A 

in reconstructing several status items, SC&A recently updated this matrix and provided it to the 

work group and NIOSH on March 11, 2022, for review and use in upcoming discussions 

(SC&A, 2022). This matrix is attached to this report as attachment A for convenience. An 

updated version of SC&A’s internal October 2021 SEC issues status update is provided as 

attachment B.8

8

 Note that the version in attachment B has been modified slightly for accuracy based on a teleconference between 

SC&A and NIOSH in January 2022; the recent changes are noted in the attachment. 

No other potential SEC issues have been identified by SC&A for the 1972–2007 period, with the 

possible exception of the scope of CTWs that can and should be addressed by the 

aforementioned co-exposure models. The recently designated SEC class identified sCTWs as the 

worker cohort whose exposure potential would likely be higher than other CTWs due to their 

nonroutine work assignments involving “short-term high-exposure work tasks,” with an

attendant “lack of assurance provided their bioassay monitoring, and identified gaps in the 

permit-driven job-specific monitoring program” at SRS for at least 1972–1990 (ABRWH 2021, 

p. 1, attachment p. 2). However, it is evident that other CTWs, as a whole, performed similar 

RWP tasks, sometimes side-by-side with sCTWs having similar exposure potentials, although 

the former likely would have been less transitory in their work tasking. Programmatically, the 

lack of assurance provided their job-specific bioassay monitoring would have impacted CTWs 

on job plans and RWPs, the same as for sCTWs. Currently, the distinction being made between 

the two worker categories stems from a subjective judgment of the higher exposure potential of 

sCTWs, an issue raised early and extensively analyzed by both NIOSH and SC&A during the 

prior SEC evaluation review.9

9 This analysis was part of the work group’s review of stratification for co-exposure model development: 

beginning with NIOSH’s 2017 presentation comparing DuPont CTWs with DuPont sCTWs for plutonium analysis, 

1956–1988, as a means to compare 95th percentile urinary excretion rates in support of sCTWs being included in the 

same cohort as CTWs, followed by a NIOSH white paper (NIOSH, 2019c), an SC&A response (SC&A, 2019b), and 

a NIOSH response (NIOSH, 2020a). Based on its analyses, NIOSH’s position is “that the exposure conditions and 

the potential for intakes were similar among all CTWs (prime and subcontractor), therefore a combined strata is 

appropriate” (NIOSH, 2020a, slide 21).

That assessment needs to be balanced against data incompleteness 

for both cohorts stemming from job-specific bioassays not necessarily being performed reliably 

and adequately for required radionuclides. In the context of bioassay data completeness and
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representativeness under DCAS-IG-006, revision 00, “Criteria for the Evaluation and Use of 

Co-exposure Datasets” (NIOSH, 2020b), the distinction between sCTWs and CTWs on permitdirected, job-specific bioassays bears further work group deliberation in the context of this 

review. 
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7 Summary Conclusions

Based on the reviews discussed in this report, SC&A has the following conclusions:

1. Sampling premise is not sufficiently grounded in historical SRS practices. Measured 

against the review criteria used by SC&A’s review of RPRT-0092, the sampling premise 

is not sufficiently grounded in actual WSRC policies, procedures, and practices within 

the time period 1991–1998. While RWPs were implemented by procedure in 1992 (and 

were being rolled out by WSRC before then), along with more specific target 

radionuclides listed on RWPs, SC&A finds that demonstrable implementation of these 

requirements was not apparent in the workplace until 1994–1995, as evidenced by 

figure 1 and table 2. Figure 1 shows that the percentage of required bioassays listed on 

the RWPs rose from very few (less than 5 percent) in 1991–1993 to over 60 percent in 

1994 and over 80 percent in 1995. Correspondingly, table 2 shows that the percent of 

RWP-specified radionuclide bioassays compared to total bioassays listed in table C-1 of 

RPRT-0092 rose for plutonium from zero percent in 1991 to 78 percent and 100 percent

in 1994 and 1995, respectively. While these results could also imply that prescheduled 

bioassays were actually performed in place of job-specific bioassays but simply not cited 

on the RWPs, they also indicate that RWPs may have lacked adequate documentation and 

completeness. (Table 2 also notes that for other radionuclides of concern—americium, 

uranium, and neptunium—the percent of radionuclide-specific bioassays required by 

RWPs ranged from zero to 25 percent for 1991–1993). While RPRT-0092 finds a 

relatively high level of direct and effective matches for sCTWs listed on RWPs, this may 

not be a valid comparison for the sake of bioassay data representation, given the nascent 

state of RWP program implementation that may bias the percentage of sCTWs 

bioassayed higher for the already prescheduled radionuclides of concern (e.g., plutonium, 

americium, and fission products).

2. Results for direct and effective monitoring may be overstated. SC&A continues to 

conclude that, as with the earlier SEC period of 1972–1990, NIOSH did not address all of 

the radionuclides listed in the RWPs when determining data completeness for jobspecific bioassay monitoring, and, therefore, the percentage of matching results for direct 

and effective monitoring appear to be overstated in the RPRT-0092 summary in 

section 6.3. This is most relevant for the 1991–1994 period, when (as noted in 

conclusion 1) many exposure-relevant radionuclides of concern were not yet included in 

RWPs and inaccurate facility source term assumptions may have been made, as noted by 

DOE in 1990 (DOE, 1990) and by WSRC in 1999 (WSRC, 1999a). While RPRT-0092 

claims a relatively high percentage of both direct and effective matches between RWPs 

and listed sCTWs or their coworkers for at least one bioassay (averages of 96 and 

98 percent, respectively), SC&A’s review found these values to be lower (averages of 

77 percent directly and 89 percent effectively monitored) when matched against all 

mandated radionuclides for RWPs. These results tend to be dampened in a sitewide 

comparison, given the much larger numbers of prescheduled bioassays (plutonium, 

Sr/FPs, uranium), but become more apparent at the facility level, as shown in tables 5, 6,

and 7. For the period 1991–1994, there are facility-specific instances of significantly 

lower percentages of directly bioassayed sCTWs (e.g., 50 percent for uranium at A-773 

and at F-247 in 1991, as shown in table 7). RWPs themselves would not necessarily have 
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included complete in vitro bioassay requirements until March 1999, when WSRC 

expanded its bioassay specifications to include facility-specific analytic characterization 

information (WSRC, 1999a).

3. Generalized matching is not sufficient. Concerning co-exposure model datasets, SC&A 

found in a focused review of RPRT-0092 plutonium coworker matches during the 1991–

1998 WSRC period that, while nearly 96 percent of identified coworker matches 

involved the same RWP, inclusion of additional criteria (e.g., the same date, time, and 

craft) decreases this percentage significantly (down to 45 percent) (SC&A, 2019a, p. 66). 

Given the often nonroutine and intermittent nature of sCTW jobs under RWPs, 

sometimes involving unique radiological source terms, SC&A believes such matching 

needs to be more closely aligned with what is listed on the actual RWP. While the 

co-exposure implementation guide (NIOSH, 2020b) does not specify an objective 

measure for data completeness to support the representativeness of a co-exposure model, 

it does require a determination be made that “there are sufficient measurements to ensure 

that the data are either bounding or representative of the exposure potential for each 

job/exposure category at the facility” (NIOSH, 2015, p. 5). SC&A does not consider a 

generalized match of workers to RWP-specified, job-specific bioassays to satisfy the 

need to demonstrate that this data set is either bounding or representative of subcontractor 

exposure potential that should have been monitored by job-specific bioassay. 

4. RWP-specified, job-specific bioassay data are incomplete. RWP-required, job-specific 

bioassay data should be assumed to be substantially incomplete for purposes of 

demonstrating monitoring data completeness and representativeness for use in a 

co-exposure model until the end of 1996 (a 100-percent resampling of all workers on jobspecific bioassays was performed for 1997; enhanced accountability and tracking of jobspecific bioassays were implemented in 1998). This is based on independent program 

audits that found that lapses in bioassay submission existed during the 1991–1996 

timeframe, spanning from the initial 1990 Tiger Team findings about bioassay program 

noncompliance to the 1997–1998 WSRC actions in response to DOE field audits, internal 

FEB findings, and DOE headquarters enforcement action. This is consistent with 

SC&A’s analysis in figures 4 and 5, where SC&A compared the noncompliance fraction 

(missed bioassay results) of directly bioassayed radionuclides (plutonium, uranium, 

americium, Sr/FPs neptunium), in terms of being greater or lower for the period 1991–

1994, as compared with 1995–1998, respectively. These comparisons are most evocative 

for uranium and americium, with bioassay noncompliance being significantly higher for 

the earlier period. The opposite is true for neptunium and Sr/FPs, but by only a small 

margin over fewer data points. As expected, plutonium is essentially the same for both 

periods, likely due to its outsized prevalence in SRS operations and by its prescribed, 

prescheduled monitoring 

5. Feasibility of co-exposure model needs to balance RWP implementation with 

completeness of coworker data. Given conclusion 4, it is also clear that sCTWs who 

were on RWPs and may not have been monitored likely worked alongside coworkers 

who were monitored according to the RWP requirements. If RWPs can be considered 

complete and adequate (because the concerns identified in conclusions 1 and 2 have been 

addressed) and implemented in an accountable manner with the requisite bioassays 
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substantially performed (per conclusion 4), SC&A would consider NIOSH’s conclusion 

valid that the RPRT-0092 sampling review demonstrates sufficient matches (direct and 

effective) in the 1991–1998 period to support development of a co-exposure model for 

sCTWs on job-specific bioassays who lacked internal monitoring data. While job-specific 

bioassays and source terms may be incomplete, given the programmatic shortfalls, this is 

mitigated by two considerations: (1) job-specific bioassays made up only 5 percent of 

total bioassays by 199710 and (2) a full resampling of job-specific bioassay results for the 

second quarter of 1997 found no evidence of intakes. Accordingly, a conclusion about the 

feasibility of a co-exposure model for workers lacking bioassay results for nonroutine 

work may be reached by balancing the programmatic limitations of the RWPs and jobspecific bioassays with the availability of suitable coworker bioassay data (as given in 

RPRT-0092). 

10 This is demonstrated by a WSRC self-assessment of internal monitoring program participation in May 1997, 

although this one-time sampling is not necessarily applicable to earlier years and it is evident that the numbers of 

subcontractors on site at SRS peaked in the early 1990s (as illustrated by, among other sources, the NOCTS dataset 

(NIOSH, 2019d).

To summarize, the issue of data completeness and representativeness in this instance are clearly 

a subjective measure that must weigh two things against one another: (1) programmatic evidence 

(i.e., the temporal nature of procedural development, implementation, and realization in light of 

the documented program deficiencies) and (2) the observed monitoring results for sCTWs in the 

available sample of RWPs (i.e., the RPRT-0092 dataset). Programmatic evidence indicates that 

the job-specific monitoring program and source characterization was a developing program 

during the 1990s and that there were documented deficiencies found by both DOE and WSRC as 

late as 1999 (e.g., 79 percent noncompliance in the job-specific program). For observed 

monitoring results, a sampling of RWPs during this same period indicates that many workers 

were directly monitored11 or on the same RWP as an assumed coworker who was monitored, 

resulting in their being effectively monitored.12 The majority of these monitoring results are 

logically a result of enrollment in the pre-scheduled, routine program and thus do not obviate the 

deficiencies in completeness of the job-specific monitoring program. However, it must be 

determined if, and when, the observed coverage of the routine monitoring program is sufficient 

to justify the representativeness of any subsequent co-exposure model as applied to workers who 

should have been covered by the deficient job-specific program.

11 Seventy to 95 percent depending on the year, per SC&A’s calculation of direct monitoring for all 

assumed/required radionuclides associated with a given RWP. 

12 Eighty-three to 99 percent depending on the year, per SC&A’s calculation of effective monitoring for all 

assumed/required radionuclides associated with a given RWP. 

Regarding other SEC-relevant issues for SEC-00103, SC&A has found no outstanding issues 

other than (1) the need to reconcile the scope of the CTW cohort that can and should be 

addressed by existing co-exposure models, and (2) several remaining action items for work 

group discussion and closure from previous issues matrices (these are listed and updated in 

attachments A and B).
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8 References

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Anderson, Chair, ABRWH, to Xavier Becerra, Secretary, Department of Health and Human 

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Augusta Chronicle. (1998, January 8). SRS workers failed to take required test [Interview with 

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Findley, W. M. (1997, November 7). Understanding urine bioassay sampling (rev. 3). 

Westinghouse Savannah River Company. SRDB Ref. ID 167760 

Findley, M. (2010). Interview with Mitch Findley, conducted by SC&A and NIOSH at Savannah 

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LaBone, T., & Findley, M. (2013). Documented communication with Tom LaBone and Mitch 

Findley, MJW Corporation, conducted by SC&A and NIOSH, April 29, 2013. 

National Institute for Occupational Safety and Health. (2008). SEC petition evaluation report 

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National Institute for Occupational Safety and Health. (2010, July 19). NIOSH action item list: 

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National Institute for Occupational Safety and Health. (2015). Draft criteria for the evaluation 

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operations at Savannah River Site (ORAUT-RPRT-0065, rev. 00). 

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Site (ORAUT-RPRT-0077, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt77-r0.pdf 

National Institute for Occupational Safety and Health. (2017a). Locations of stable metal tritide 

use at the Savannah River Site (ORAUT-RPRT-0072, rev. 00).

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plutonium fuel facility construction workers in Building 235-F at the Savannah River Site 

(ORAUT-RPRT-0080, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-80-

r0.pdf
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assessment of thorium-232 exposures at the Savannah River Site from 1972 to 1989 (ORAUTRPRT-0070, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-70-r0.pdf 

National Institute for Occupational Safety and Health. (2017d). Appropriateness of using 1997 

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farm between 1972 and 1994 (ORAUT-RPRT-0081, rev. 00). 

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(ORAUT-RPRT-0092, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-92-

r0-508.pdf 

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Site americium-241 source terms between 1971 and 1999 using bioassay frequency tables

(ORAUT-RPRT-0091, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-91-

r0-508.pdf

National Institute for Occupational Safety and Health. (2019c). Savannah River Site plutonium 

construction trade worker stratification refinement [White paper]. 

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National Institute for Occupational Safety and Health. (2019d). Bioassay for subcontractor 

construction trade workers at the Savannah River Site from 1972 to 1997 (ORAUT-RPRT-0094, 

rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-94-r0-508.pdf 

National Institute for Occupational Safety and Health. (2020a). Savannah River Site plutonium 

construction trade worker stratification refinement [NIOSH presentation at the SRS and SEC 

Issues joint work group meeting, November 20, 2020]. 

https://ftp.cdc.gov/pub/FOIAREQ/183768-508.pdf 

National Institute for Occupational Safety and Health. (2020b). Criteria for the evaluation and 

use of co-exposure datasets (DCAS-IG-006, rev. 00).

https://www.cdc.gov/niosh/ocas/pdfs/dr/dc-ig-006-r0-508.pdf

SC&A, Inc. (2005). Review of NIOSH site profile for Savannah River Site (SCA-TR-TASK1-

0003, rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srssp-r0.pdf

SC&A, Inc. (2009). Issues matrix for the Savannah River Site SEC petition and petition 

evaluation report. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2009/srsmatrix0909.pdf

SC&A, Inc. (2011, January 20). Matrix issues 22 and 23 regarding petitioner external dose 

issues [Memorandum]. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srssecim012011.pdf

SC&A, Inc. (2014a). Issues matrix for the Savannah River Site SEC petition and petition 

evaluation report. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srsimsec103-0214.pdf
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SC&A, Inc. (2014b, June 6). SC&A’s current evaluation of the SRS SEC matrix issue 3 – 

recycled uranium [Memorandum]. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scasrssecim3-060614.pdf 

SC&A, Inc. (2017). Evaluation of Savannah River Site subcontractor bioassay data 

completeness (SC&A-TR-2017-SEC009, rev. 0 PC-1). 

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SC&A, Inc. (2019a). Review of ORAUT-RPRT-0092, revision 00, “Evaluation of bioassay data 

for subcontracted construction trade workers at the Savannah River Site” (SCA-TR-2019- 

SEC005, rev. 0). https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srsrprt92r0-508.pdf 

SC&A, Inc. (2019b, November 12). Review of NIOSH’s refined construction trade worker 

stratification comparisons for plutonium [Memorandum]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srssectw-111219-508.pdf 

SC&A, Inc. (2021, October 25). Updated status of SEC-00103-related issues [Informal internal 

memorandum to the Savannah River Site and SEC Issues work groups]. SRDB upload pending 

SC&A, Inc. (2022, March 11). March 2022 update of issues matrix for the SRS SEC petition and 

petition evaluation report [Memorandum].

U.S. Department of Energy. (1990). Tiger Team assessment of the Savannah River Site

(DOE/EH-0133). SRDB Ref. ID 46767 

U.S. Department of Energy. (1998a). Preliminary notice of violation and proposed imposition of 

civil penalty - $75,000 (NTS-SR--WSRC-ESH-1997-0001) [letter from Peter N. Brush, Acting 

Assistant Secretary for Environment, Safety and Health, to Mr. Ambrose L. Schwallie, Manager, 

Westinghouse Savannah River Company, September 21, 1998]. 

https://www.energy.gov/sites/prod/files/2013/08/f2/ea98-09R1.pdf 

U.S. Department of Energy. (1998b). Inadequate participation in the job-specific bioassay 

program (Occurrence Report EM-SR—WSRC-MOGEN-1997-0005). SRDB Ref. ID 167487 

[Redacted]

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and Human Services designation of additional members of the Special Exposure Cohort under 

the Energy Employees Occupational Illness Compensation Program Act of 2000: Designating a 

class of employees from Savannah River Site Aiken, South Carolina. 

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U.S. General Accounting Office. (1990). Nuclear safety: Concerns about reactor restart and 

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Westinghouse Savannah River Company. (1990a). Savannah River Site action plan (DOE/SR3507, vol. 1, rev. 3). SRDB Ref. ID 178307 

Westinghouse Savannah River Company. (1990b). Internal dosimetry technical basis manual

(WSRC-IM-90-139). SRDB Ref. ID 011266 

Westinghouse Savannah River Company. Radiation and contamination control procedures, 

manual 5Q1.1, procedure 506 (rev. 0). SRDB Ref. ID 152159, PDF p. 55 ff. 

Westinghouse Savannah River Company. (1993). Savannah River Site internal dosimetry 

technical basis manual (WSRC-IM-90-139, rev. 2). SRDB Ref. ID 173926 

Westinghouse Savannah River Company. (1997). The Savannah River Site internal dosimetry 

technical basis manual (WSRC-IM-90139, rev. 6). SRDB Ref. ID 173927 

Westinghouse Savannah River Company. (1998a, December 14). Status of SRS bioassay 

program relative to DOE moratorium [Interoffice memorandum] (ESH-HPT-98-0552). SRDB 

Ref. ID 167756 

Westinghouse Savannah River Company. (1998b, August 13). Specification of bioassay 

requirements on Radiological Work Permits (ESH-HPT-98-0453) [WSRC interoffice 

memorandum]. SRDB Ref. ID 167753 

Westinghouse Savannah River Company. (1998c, July 16). Bioassay program deficiencies

(ESH-HPT-98-0408) [WSRC interoffice memorandum]. SRDB Ref. ID 167686 

Westinghouse Savannah River Company. (1998d, January 19). Root cause analysis for 

Corrective Action Report #97-CAR-07-0001, Attachment A [WSRC interoffice memorandum].

SRDB Ref. ID 167757, PDF pp. 8–93. 

Westinghouse Savannah River Company. (1999a, March 10). Specification of urine bioassay 

requirements on radiological work permits [Memorandum]. SRDB Ref. ID 167754 

Westinghouse Savannah River Company. (1999b, November 2). Response to the compilation of 

PAAA internal dosimetry issues (U) (ESH-HPT-99-0226) [Interoffice memorandum]. SRDB 

Ref. ID 167676 

Westinghouse Savannah River Company. (2002, June 27). Radiological control program for 

special tritium compounds (U) (ESH-HPT-2002-00096) [WSRC interoffice memorandum].

SRDB Ref ID 45992

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radionuclides of interest in a facility radiobioassay program (U) [WSRC interoffice 

memorandum]. SRDB Ref. ID 167846 
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Attachment A: Issues Matrix for SRS

[This attachment reproduces a March 11, 2022, SC&A memorandum to the Savannah River Site 

and SEC Issues work groups, “March 2022 Update of Issues Matrix for the SRS SEC Petition 

and Petition Evaluation Report.”] 

On behalf of the Savannah River Site (SRS) work group, SC&A maintained and updated a 

Special Exposure Cohort (SEC) issues matrix, starting in September 2009, that compiled all 

identified exposure potential issues at SRS based on the work group’s review of Petition SEC 

00103. The original 2009 matrix (SC&A, 2009a) was based on issues that were unresolved from 

the SC&A review of the SRS site profile and SC&A’s preliminary review of NIOSH’s 

evaluation report (ER) (NIOSH, 2008). The initial 2009 matrix listed 25 issues of SEC 

relevance; an additional issue was added later, for 26.

SC&A issued an updated 2014 SEC issues matrix (SC&A, 2014) in February 2014 following the 

designation of an SEC class for all SRS employees for 1953–1972. This designation rendered 

moot some SEC issues, while others needed additional research to address questions related to 

latter time periods, including those for construction trade workers (CTWs), nuclide-specific 

issues (e.g., neptunium, special tritium compounds, and thorium), and co-exposure modeling. For 

this current review, SC&A reviewed the 2014 matrix (the latest generated) to confirm any 

outstanding issues for which documented resolution is not apparent. 

Of the 26 SEC-relevant issues listed in the 2014 matrix, three issues lacked a documented 

resolution: issue 3 for “Recycled Uranium,” issue 22 for “Badges not capturing dose,” and issue 

26 for “additional worker and worker representative issues.” 

The original recycled uranium (RU) issue, which was identified in SC&A’s 2005 site profile 

review (SC&A, 2005), found that a timeline for RU operations had not been issued and it was 

not clear when and how RU (with trace radiological contaminants) may have been handled at 

SRS. NIOSH issued trace contaminant data for RU in 2010 (NIOSH, 2010b), and SC&A 

responded with a memorandum about remaining RU issues in 2014 (SC&A, 2014b). While there 

is no confirmation of an outstanding SEC issue, no final resolution was apparent in the work 

group records on this matter. 

For issue 22 (and subsumed issue 23), SC&A had found that worker interviews indicated that 

some workers kept their badges out of higher radiation areas in order to not exceed dose limits 

(SC&A, 2011c) and that badge dose readings may have been under-recorded or not recorded. 

NIOSH was to review SC&A’s report of these worker interviews and provide a response.

For issue 26, SC&A had compiled and categorized a number of worker and petitioner comments 

about specific workplace issues for which a specific NIOSH response has not been received to 

date. However, as noted in SC&A’s updated matrix in this memo, a number of the comments are 

addressed in existing SEC issues reviewed by the work group and NIOSH. 

A number of other SEC-relevant issues from the 2014 matrix have either been closed, resolved, 

subsumed under other issues, or superseded by the 2011 Board action to recommend an SEC for 

1953–1972 (issues 1, 8, 12, 15, 16, 17, 18, 19, 21, 23, 24, and 25). Still others are being 
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addressed by the development of co-exposure models under ORAUT-OTIB-0081, “Internal 

Dosimetry Co-Exposure Data for the Savannah River Site”: issue 2 for thorium via ORAUTRPRT-0070 (NIOSH, 2017a) and ORAUT-RPRT-0081 (NIOSH, 2017d); issue 4 for trivalent 

actinides and thorium; issues 6 and 7 for fission and activation products; issue 9 for tritium; and 

issue 13 for comparing intakes for CTWs versus non-construction workers. Issue 5 for 

neptunium (Np)-237 has been addressed by NIOSH in ORAUT-RPRT-0065 (NIOSH, 2016a), 

ORAUT-RPRT-0077 (NIOSH, 2016b), and ORAUT-RPRT-0080 (NIOSH, 2017c) and is being 

handled by the work group as an ongoing issue. Issue 10 for special tritium compounds, which 

are being addressed as “Metal Hydrides” in ORAUT-RPRT-0072 (NIOSH, 2017b), is also 

ongoing. Issue 11 (exotic radionuclides), issue 14 (special exposure conditions), and issue 20 

(tank farm geometry) have reached the resolution stage and are ready for work group review for 

closure. 

Other than the three specific outstanding items—issues 3, 22, and 26, none of which have been 

judged SEC-significant to date—SC&A has determined that the relevant SEC issues have flowed 

down to and have been included in subsequent priority action lists presented by NIOSH to the 

work group. Their status is summarized in SC&A’s informal internal update of SEC-00103 

issues status in October 2021 (SC&A, 2021). 

Given how long ago this 2014 issues matrix was last updated and the challenge faced by SC&A 

in reconstructing several status items, SC&A recommends to the work group that the 2022 

updated matrix13 included in this memo be reviewed and corroborated by NIOSH and the work 

group. 

13 Please note that the structure of the 2014 matrix has been updated and the text proofread and reformatted to 

comply with current NIOSH requirements for Section 508 compliance. 
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Table A-1. March 2022 update of issues matrix for the SRS SEC petition and petition ER

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

1 Thorium up to 1965 7.1.1.8 Thorium work was carried out in a 

number of areas and dose 

reconstruction methods need to be 

specified. NIOSH had reserved the 

issue for further research up to 1960 

in the ER (NIOSH, 2008), but 

extended the date to 1965 when it 

published an addendum to the ER in 

May 2010 (NIOSH, 2010a).

NIOSH published Addendum 

2 to its ER in August 2011 

(NIOSH, 2011a) 

recommending that workers 

with certain area and 

dosimetry codes who worked 

between Jan. 1, 1953, and 

Sept 30, 1972, be added to 

the SEC because of the 

infeasibility of thorium dose 

reconstruction in certain 

buildings in this period.

SC&A did an analysis of the 

completeness of area and dosimetry 

codes in the records of 10 claimants (not 

a random sample) (SC&A, 2011e).

Update – February 21, 2014: This issue 

is resolved.

Resolved. Board 

recommended addition of all 

workers from Jan. 1, 1953, 

to Sept. 30, 1972, to the 

SEC. Includes CTWs and 

non-construction workers 

(NCWs). 

2 Thorium, 1965 onwards 7.1.1.8 Thorium 1965 and after. No coworker 

model or specific approach to 

bounding dose was provided in the 

ER.

Refer to issue 1 up to 

September 30, 1972. NIOSH 

is researching the thorium 

issue after that date.

SC&A has provided draft reports to the 

Board indicating some thorium work after 

Sept. 30, 1972.

Update – February 21, 2014: NIOSH 

has published Addendum 3 to its ER 

(NIOSH, 2012a). NIOSH has also 

published its internal coworker dosimetry 

data in NIOSH 2013a and a revision of 

that document (NIOSH, 2013b). SC&A 

has reviewed NIOSH 2012a and the 

data relating to thorium that NIOSH 

proposes to use (SC&A, 2013a). NIOSH 

has responded to SC&A’s review 

(NIOSH, 2014a). SC&A is reviewing the 

new information in NIOSH 2013b and 

NIOSH 2014a and provided its 

comments during the Work Group 

meeting held on February 5, 2014, and 

will provide further comments during the 

conference call scheduled for February 

26, 2014. SC&A’s review of NIOSH SRS 

coworker models is connected with its 

review of NIOSH’s proposal to aggregate 

internal monitoring data according to a 

“One Person-One Sample” (OPOS) 

method, as described in NIOSH 2012b. 

SC&A’s review of the OPOS method, in 

Resolved up to Sept. 30, 

1972. Open after that.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

general, has been issued to the SEC 

work group. SC&A’s review of OPOS 

includes some SRS-specific matters. 

SC&A’s SRS-specific finding is that SRS 

NCW data cannot be used for the 

estimation of unmonitored CTW internal 

doses for a variety of reasons. NIOSH 

disagrees and contends that it can.

Update – March 2022: NIOSH issued 

ORAUT-RPRT-0070, “Evaluation of 

Method for Assessment of Thorium-232 

Exposures at the Savannah River Site 

from 1972 to 1989” (NIOSH, 2017a). 

This document discusses a new method 

for bounding potential internal doses 

from thorium using known inventories 

and routine air monitoring data. 

Following issuance of Addendum 3, 

NIOSH learned that the method used to 

analyze urine samples for trivalent 

radionuclides was changed in 1990 to 

alpha spectroscopy, which rendered the 

proposed use of trivalent radionuclide 

bioassay coworker data impracticable. 

SC&A provided comments in an October 

2018 response (SC&A, 2018), with one 

finding re alternate sampling methods as 

applied to decontamination and 

decommissioning and off-normal 

sources. NIOSH responded in December 

2018 and agreed with SC&A’s finding 

and clarified that “the intake rate 

associated with these data should only 

be used for normal conditions,” with a 

50th percentile co-worker intake applied 

for off-normal circumstances (NIOSH, 

2018, p. 5). This issue appears to be 

resolved, although work group closure is 

needed.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

3 Recycled uranium (RU) 7.1.1.2 This issue is in part a carry-over from 

the SC&A technical basis document 

(TBD) review (SC&A, 2005, p. 71). A 

timeline for the RU operations has not 

been published.

Some revised trace 

contaminant data were 

provided in July 2010 

(NIOSH, 2010b) using U.S. 

Department of Energy (DOE) 

RU publications and a 1984 

SRS document as references. 

A start date of 1955 for RU 

was provided.

SC&A started a review of the NIOSH 

ratios and associated reference material. 

Report preparation was stopped pending 

resolution of issues related to ER 

addenda.

Update – February 21, 2014: SC&A is 

preparing a review of the RU ratios; the 

review is scheduled to be completed by 

June 2014.

Update – March 2022: SC&A issued its 

review in a memorandum of June 6, 

2014, that requested clarification of 

NIOSH’s ratios and associated 

supporting material. SC&A’s major 

concern was that there were “two 

different tables provided by NIOSH, and 

it is not obvious how the values in the 

tables were derived; therefore, it is 

difficult to evaluate them” (SC&A, 2014b, 

p. 2). SC&A recommended to the SRS 

work group that NIOSH (1) restate and 

justify their recommended RU 

components and their appropriate values 

and (2) provide a description of how the 

recommended values were derived, so 

that they can be independently verified. 

This would include the location in the 

documents where the values were 

obtained, any assumptions, conversion 

factors, and other information necessary 

to trace the values NIOSH recommends. 

While no NIOSH response was found, 

this issue may have been overtaken by 

other, broader reviews of RU. SC&A 

believes this to be a matter of 

clarification, not of SEC significance.

Relevant only after Sept. 30, 

1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

4 Trivalent actinides 

americium (Am), curium 

(Cm), and californium (Cf)

7.1.1.5, 7.1.1.6, 

7.1.1.7

Trivalent actinides: Am, Cm, and Cf. 

There are no data for Cm-244 until 

1963 (ER figure 7-1). Data analysis 

and coworker models have not been 

provided for any period. Relevance of 

later data to earlier periods has not 

been established. Relationship 

between NCW and CTW intakes for 

trivalent radionuclides in the period 

before monitoring began and after 

monitoring began has not been 

established. Where NIOSH proposes 

to use gross alpha data (e.g., for Cf252, method for selecting workers for 

assigning dose and selecting the 

radionuclide) have not been 

scientifically established. The 

resulting dose estimates would need 

to be examined for validity and 

reasonableness. Cf-252 assignment 

would also need to be reviewed in 

relation to spontaneous fissionrelated organ doses (including 

neutrons from spontaneous fission 

after intake).

NIOSH proposes to use 

measured data or coworker 

models for estimating dose 

with sufficient accuracy (ER 

sections 7.1.1.5 to 7.1.1.7). 

Since data were collected for 

all three trivalent 

radionuclides rather than 

each separately, NIOSH 

proposes to assign the result 

to Cf-252 as appropriate (ER, 

p. 51). NIOSH has not yet 

published its coworker model. 

NIOSH has specified an 

International Commission on 

Radiological Protection 

(ICRP) model for Cf-252 

spontaneous fission.

SC&A awaits the coworker model and 

will review it when it is available. SC&A 

agrees with NIOSH regarding the ICRP 

model for Cf-252. 

Update – February 21, 2014: NIOSH 

has published a coworker model for 

trivalent actinides (NIOSH, 2012d). Many 

of the findings for thorium in SC&A 

2013a apply to NIOSH’s proposed 

methods for coworker trivalent actinide 

dose estimation because NIOSH 

proposes to use trivalent actinide 

monitoring data for thorium dose 

reconstruction. Therefore, SC&A has not 

reviewed NIOSH 2012d as such, 

pending resolution of the findings in 

SC&A 2013a that also apply to NIOSH 

2012d. SC&A notes that SC&A 2013a 

does not address adequacy or 

completeness of SRS trivalent actinide 

data for coworker modeling of those 

three radionuclides (Am, Cm, Cf).

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, “Internal 

Coworker Dosimetry Data for the 

Savannah River Site,” with findings and 

observations discussed by the work 

group. Additional reviews were 

conducted regarding multiple imputation 

methods and trivalent bioassay 

variability. Remaining issues are before 

the work group for discussion and are 

summarized in the October 25, 2021, 

internal memorandum, “Updated Status 

of SEC-00103-Related Issues” (SC&A, 

2021).

SC&A has not checked the 

ending date for these 

radionuclides. Now only 

relevant after Sept 30, 1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

5 Np-237 7.1.1.4 Data analysis and coworker model 

not provided. Adequacy of data for 

coworker model not established. 

Applicability of back-extrapolation of 

data from 1960s and after to pre-1960 

period not established. 

NIOSH proposes to use data 

for the workers who were 

monitored to reconstruct their 

dose and a coworker model 

for the rest. Data available 

from 1960 onward in claimant 

database. NIOSH has not yet 

published its coworker model.

SC&A awaits the coworker model and 

will review it when it is available.

Update – February 21, 2014: NIOSH 

has published a coworker model for Np237 (NIOSH, 2012c), which SC&A has 

reviewed (SC&A, 2013b). NIOSH has 

responded to SC&A’s review (NIOSH, 

2014b). SC&A provided its comments 

regarding NIOSH 2014b at the meeting 

held on February 5, 2014, and will 

provide further comments during the 

during the work group conference call 

scheduled for February 26, 2014. 

SC&A’s review of NIOSH SRS coworker 

models is connected to its review of 

NIOSH’s proposal to aggregate internal 

monitoring data according to an OPOS 

method (NIOSH, 2012b). SC&A’s review 

of the OPOS method, in general, has 

been issued to the SEC work group. 

SC&A’s review of OPOS includes some 

SRS-specific matters. SC&A’s SRSspecific finding is that SRS NCW data 

cannot be used for the estimation of 

unmonitored CTW internal doses for a 

variety of reasons. NIOSH disagrees and 

contends that it can.

Update – March 2022: NIOSH issued 

RPRT-0065 (2016a, neptunium 

operations), RPRT-0077 (2016b, codes), 

and RPRT-0080 (2017c, Plutonium Fuel 

Form Facility), with SC&A and NIOSH 

exchanging responses for all three 

reports. The outstanding issues await 

work group discussion and resolution 

and are summarized in SC&A’s October 

25, 2021, memorandum, “Updated 

Status of SEC-00103-Related Issues” 

(SC&A, 2021).

Now relevant only after 

Sept. 30, 1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

6 Fission and activation 

products

7.1.1.9 Validity of back-extrapolation of 

strontium (Sr)-90 data has not been 

established. Adequacy of fission 

product monitoring data for coworker 

model has not been established. ER 

states that strontium radioisotope 

monitoring began in the “late 1950s.” 

The proposed coworker model has 

not been published.

NIOSH has not yet published 

its coworker model.

SC&A awaits the coworker model and 

will review it when it is available.

Update – February 21, 2014: NIOSH 

has published a coworker model for 

mixed fission and activation products 

(NIOSH, 2012e). Some of the findings 

for thorium and neptunium in SC&A 

2013a and SC&A 2013b apply to 

NIOSH’s proposed methods for mixed 

fission and activation products. SC&A 

has not reviewed NIOSH 2012e as such, 

pending resolution of the findings in 

SC&A 2013a and SC&A 2013b that also 

apply to NIOSH 2012e. SC&A notes that 

SC&A 2013a and SC&A 2013b do not 

address adequacy or completeness of 

SRS mixed fission and activation product 

data for coworker modeling of those 

radionuclides.

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, with findings and 

observations discussed by the work 

group. Remaining issues are before the 

work group for discussion and are 

summarized in SC&A’s informal, internal 

October 25, 2021, memorandum, 

“Updated Status of SEC-00103-Related 

Issues” (SC&A, 2021).

Now relevant only after 

Sept. 30, 1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

7 Co-60 7.1.1.10 Validity of use of fission product data 

prior to 1960 has not been 

established. Coworker model has not 

been published. ER does not address 

the issue of incidents. Individual 

bioassay data or coworker model 

based on claimant data will be used. 

Targets were encapsulated (comment 

in TBD matrix). The potential 

similarity of the irradiation of 

encapsulated sources is noted in the 

July 7, 2007, work group meeting 

notes.

NIOSH has not yet published 

its coworker model.

SC&A awaits the coworker model and 

will review it when it is available.

Update – February 21, 2014: NIOSH 

covered cobalt (Co)-60 in its report on 

“exotic radionuclides” (NIOSH, 2012f). 

NIOSH states that whole body counting 

data are available. There is no indication 

of production after October 1, 1972, in 

NIOSH 2012f. SC&A has not reviewed 

NIOSH 2012f.

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, with findings and 

observations discussed by the work 

group. Remaining issues are before the 

work group for discussion and are 

summarized in SC&A’s informal, internal 

October 25, 2021, memorandum, 

“Updated Status of SEC-00103-Related 

Issues” (SC&A, 2021).

Now relevant only after 

Sept. 30, 1972.

8. Po-210 7.1.1.11 The coworker model has not been 

published. Incidents are not 

addressed. Relationship of CTW to 

NCW intakes has not been 

established.

NIOSH published a paper on 

polonium (Po)-210 in January 

2011 (NIOSH, 2011b). The 

Po-210 program at SRS 

ended in 1970.

No review needed.

Update – February 21, 2014: NIOSH’s 

report on exotic radionuclides (NIOSH, 

2012f) includes further information on 

Po-210 and does not provide any 

indication of production of Po-210 after 

October 1, 1972. SC&A has not further 

checked the ending date for Po-210 

production at SRS. SC&A recommends 

that this issue be tentatively closed.

Update – March 2022: Awaits work 

group action.

Resolved by the Board SEC 

vote. Ending date may need 

to be checked.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

9 Tritium 7.1.1.1 NIOSH has not demonstrated that the 

TBD approach of applying 

environmental doses to unmonitored 

workers (no badge, no bioassay) and 

reporting level to workers with 

external monitoring only is suitable for 

unmonitored CTWs. NIOSH has not 

demonstrated that it has a bounding 

dose approach for tritium for CTW.

NIOSH published a report on 

use of tritium data for CTW 

exposure estimation in 

November 2010 (NIOSH, 

2010c). NIOSH is preparing a 

second part of this report that 

specifically addresses CTW 

vs. NCW exposure.

SC&A published a report that included 

tritium, comparing CTW and NCW data, 

in January 2010 (SC&A, 2010b) and 

another in November (SC&A, 2010c) 

using a larger tritium bioassay database 

provided by NIOSH. Both indicate that 

CTWs had higher bioassays than NCWs 

in some areas, some periods, and some 

job types. SC&A will produce a single 

review of NIOSH’s tritium report when 

the second part is published.

Update – February 21, 2014: NIOSH 

published Part 2 of its tritium report in 

November 2011 (NIOSH, 2011c). SC&A 

has not resumed its review of tritiumspecific issues pending resolution of 

findings relating to issues 2, 4, 5, and 6, 

as well as general issues relating to the 

methods by which CTW and NCW 

monitoring data can be compared and/or 

combined (matrix issue 13).

Update – March 2022: SC&A reviewed 

rev. 03 (NIOSH, 2016c; SC&A, 2017) 

and rev. 04 (NIOSH, 2019; SC&A, 2020) 

of ORAUT-OTIB-0081, with findings and 

observations discussed by the work 

group. Remaining issues are before the 

work group for discussion and are 

summarized in the October 25, 2021, 

memorandum, “Updated Status of SEC00103-Related Issues” (SC&A, 2021).

Only the data from Oct. 1, 

1972, onward will be 

evaluated. There have been 

tritium/tritides-related data 

capture visits and interviews 

(NIOSH and SC&A). SC&A 

tritium interview summary 

has been merged with a 

prior summary of other 

issues. Combined summary 

is being sent to DOE for 

classification review.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

10 Special tritium 

compounds for CTWs

NA ER refers to ORAUT-OTIB-0066 

(NIOSH, 2007b) for special tritium 

compound exposure. Relationship of 

CTW to NCW exposure to special 

tritium compounds or some other 

means of bounding CTW exposure to 

them needs to be established. OTIB0066, which discusses a method to 

calculate doses due to exposure to 

special tritium compounds, is not 

specific to SRS and does not discuss 

dose reconstruction issues for such 

compounds specific to CTWs.

The solubility of one—

lanthanum-nickel hydride—is 

under investigation at SRS. 

NIOSH is completing a draft 

of its interview notes.

SC&A awaits the NIOSH approach to 

estimating tritide doses.

Update – February 21, 2014: NIOSH 

has not published any data regarding 

tritides since the last matrix update in 

2011.

Update – March 2022: NIOSH issued 

ORAUT-RPRT-0072, “Locations of 

Stable Metal Tritide Use at the 

Savannah River Site,” in 2017 (NIOSH, 

2017b). SC&A reviewed and provided 

comments in 2018 with a NIOSH 

response in 2019. No findings to date. 

Needs work group discussion and 

resolution.

Refer to issue 9 for interview 

status.

11 Exotic radionuclides 7.1.1.9 in part About 150 radionuclides were 

produced at SRS, and targets were 

fabricated there (NIOSH, 2006, 

p. 25). No analysis of the production 

processes is provided, nor are there 

any descriptions of incidents. The 

incident database is incomplete, 

which was one of SC&A’s findings in 

its TBD review. The lack of analysis 

may be parallel to the situation at Y12, where a large number of isotopes 

were produced, with the difference 

that at Y-12, they were produced in 

accelerators, and at SRS, they were 

produced in reactors. No 

documentation of the encapsulation 

processes is provided. The 

exceptions to the coverage of 

radionuclides by whole-body counting 

are not discussed. There is no 

discussion of whether any of the 

target materials were themselves 

radioactive.

NIOSH will respond to the 

SC&A report on exotic 

radionuclides. NIOSH will also 

sort out what other 

radionuclides were produced 

that are not in the SC&A 

report. NIOSH will specify 

dose reconstruction methods 

with due attention to the 

criteria for exotic 

radionuclides presented by 

Jim Neton to the Board during 

the November 2010 Santa Fe 

Board meeting.

SC&A provided the work group with a 

report on exotic radionuclides in 

December 2010 (SC&A, 2010d).

Update – February 21, 2014: NIOSH 

published a report on exotic 

radionuclides in 2012 (NIOSH, 2012f). 

SC&A 2010d raised a question whether 

an exotics production program that was 

proposed in 1969 was ever pursued. 

NIOSH did not find any evidence that it 

was (NIOSH, 2012f, p. 12). SC&A has 

not reviewed this finding. Most of NIOSH 

2012f covers the pre-1972 period. SC&A 

has not further reviewed the periods of 

exotic radionuclide production beyond 

that in SC&A 2010d.

Update – March 2022: No further 

discussion of this issue is evident. No 

apparent SEC issues have been found. 

Awaits work group disposition.

Only relevant after Sept. 30, 

1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

12 Internal dose due to 

incidents

5.2.3, 7.3.6 The Special Hazards Investigations 

list is incomplete. In its Tank Farm 

Fault Tree Databank, the site 

acknowledged that many early Tank 

Farm area incidents were not 

recorded (until 1965). The ER states 

that there are incident records, 

including the Special Hazards 

Investigation files, and that NIOSH 

has data relating to incidents (ER, 

p. 29). No evidence of cover up of 

incidents was found, and NIOSH can 

bound dose in any case (ER p. 71).

NIOSH will respond to the 

SC&A report. NIOSH may 

follow up with workers 

interviewed by SC&A. 

SC&A prepared a report on extent of and 

potential gaps in incident documentation 

in worker records to elaborate on its TBD 

review finding (SC&A, 2011b).

Update – February 21, 2014: NIOSH 

has not responded to SC&A 2011b. The 

issue remains open.

Update – March 2022: Work group 

closed this issue at February 26, 2014, 

meeting.

Interviews also indicate that 

there were unrecorded 

incidents. Only relevant after 

Sept. 30, 1972.

13 Overall CTW to NCW 

internal dose relation

7.1 ER states that ORAUT-OTIB-0052 

(NIOSH, 2007a) found NCW intakes 

“were generally higher than 

construction trades workers” (ER, p. 

39). OTIB-0052 suggests a 1:1 ratio 

for CTW to NCW intakes. SC&A 

analysis indicates that the assumption 

that NCW intakes (as indicated by 

bioassay data) would be generally 

higher than for CTW is not generally 

valid. The adequacy of bioassay data 

for constructing coworker models 

needs to be examined for different 

periods, areas, radionuclides, and 

types of CTWs.

NIOSH has produced an 

analysis of tritium data 

comparing CTWs to all 

workers (including CTWs) 

(NIOSH, 2010c). NIOSH is 

preparing a second part 

comparing CTWs to NCWs. 

NIOSH is also revising OTIB0052. NIOSH included both 

CTWs and NCWs in its 

thorium SEC recommendation 

in the ER Addendum 2 

(NIOSH, 2011a).

Besides the two reviews of CTWs vs. 

NCWs (SC&A 2010b and SC&A 2010c), 

SC&A also produced a report evaluating 

the plutonium database used in OTIB0052 (SC&A, 2010e). SC&A also 

published a master interview summary 

as part of SC&A 2011b; this summary 

contains some discussion of CTW vs. 

NCW matters. SC&A was to review 

NIOSH’s revision of OTIB-0052 when it 

is published. SC&A will await instructions 

on this issue, given the December 8, 

2011, Board vote on the SRS SEC to 

include CTWs and NCWs.

Update – February 21, 2014: This issue 

is being covered under the review of 

coworker models for specific 

radionuclides as well as in SC&A’s 

review of the NIOSH’s “One-PersonOne-Sample” aggregation of monitoring 

data. A number of findings relating to 

CTW dose reconstruction, comparison 

on NCW and CTW distributions of 

measurements, and NIOSH’s coworker 

models remain open.

Update – March 2022: This issue is 

subsumed under the work group’s 

review of OTIB-0081 and the extensive 

CTW vs. NCW resolved up 

to Sept. 30, 1972, by Board 

vote of 8 Dec. 1972 since 

both CTW and NCW were 

included in the SEC 

recommendation. Also, 

issues 19 (tentatively) and 

21 are closed. A 

considerable amount of 

work has been done by 

NIOSH and SC&A as 

indicated in the reports cited 

here. The work group had 

directed tritium data as the 

current focus of this issue to 

be followed by uranium. This 

is still an outstanding issue 

for the period after Sept. 30, 

1972. Issue may need reassessment in light of the 

inclusion of both CTWs and 

NCWs in the SEC up to 

Sept. 30, 1972.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

work group deliberations in 2017–2021

that led to an SEC class being 

designated for SRS subcontractors for 

1972–1990.

14 Special exposure 

conditions

7.4.2 There are several areas of concern 

that can be described as “special 

exposure conditions,” including offnormal or unauthorized work 

practices, burning of spent tributyl 

phosphate in open pans in the early 

years (to 1971), and high exposure 

potential during certain authorized 

work practices, such as opening tank 

risers or cleanup of high-level waste 

leaks.

NIOSH has stated that it has 

air concentration data in the 

burning ground area, and that 

it will provide a dose 

reconstruction approach.

Refer to comment column.

Update – February 21, 2014: This issue 

has been subsumed under matrix issue 

12 for the period October 1, 1972, 

through 2007.

SC&A worker interviews 

done as part of the SEC 

investigation also indicate 

off-normal practices and 

high exposure potential 

during certain types of work, 

including in the Tank Farms. 

A master summary of 

SC&A’s interviews 

(excluding tritides) is in 

SC&A 2011b. The burning 

ground issue is no longer 

relevant, since open pan 

burning ended in February 

1972 (WSRC, 2000, PDF 

p. 1068). 

15 Construction worker job 

types

NA Worker intakes and coworker models 

may have to be built by CTW job type 

in order to ensure that the models are 

bounding doses (or more accurate 

than bounding doses).

NA Update – February 21, 2014: Refer to 

update for matrix issue 13.

This issue is merged into 

issue 13.

16 OTIB-0075 validity for 

SEC use – internal dose

7.1, 7.3.4, 7.4.2 The use of ORAUT-OTIB-0075 

(NIOSH, 2009b), which asserts 

representativeness of claimant data 

for the whole worker population, for 

SRS CTW SEC is questionable.

NIOSH also produced a 

report on data with a 

significant fraction of “lessthan” results that is general, 

but also applies to the SRS 

SEC (NIOSH, 2009a).

SC&A reviewed OTIB-0075 (SC&A, 

2010b). SC&A also reviewed NIOSH 

2009a (SC&A, 2010f).

Update – February 21, 2014: Refer to 

update for matrix issue 13

This issue is merged into 

issue 13.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

17 Early neutron dose to 

1961

7.2.2.2 Fig. 7-3 of the ER (p. 65) shows no 

neutron monitoring data for the 200-F 

Area until about 1958, and generally 

less than 20 badges per cycle until 

1962 (except for part of 1959). This 

was “one of the highest neutronexposure areas at SRS,” according to 

the ER (p. 64). The entire early period 

will have to depend almost 

exclusively on area neutron and 

photon monitoring data. The 

relationship of the neutron-to-photon 

(n/p) ratio data to workers and their 

personnel neutron exposure 

experience will need to be 

established with essentially no 

reference to actual monitoring data. It 

is unclear whether there are any early 

neutron monitoring data for CTWs.

NIOSH will use an approach 

based on n/p ratios. On Feb. 

3, 2011, NIOSH reported no 

progress on this item, which 

has been pushed down the 

list of priorities due to many 

other action items. NIOSH will 

provide a date when this will 

be done. NIOSH stated it has 

the data to do dose 

reconstruction.

Update – February 21, 2014: This issue 

has been resolved.

This issue is resolved by the 

Dec. 8, 2011, Board vote.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

18 Neutron dose 1962–1971 6.2 and 7.2.2 ER acknowledges unmonitored dose 

at SRS due to neutrons, since 

monitoring was required only when 

area neutron dose rates were in 

excess of 1 mrem per hour. Neutron 

data are very sparse in general up to 

the mid-1960s, and sparse even after 

that. Representativeness of area 

monitoring for worker exposure and 

representativeness of available n/p 

data for all workers in the class needs 

to be assessed. Additionally, backextrapolation of post-1972 data was 

proposed in the TBD. It is unclear 

whether there will be backextrapolation to demonstrate 

bounding dose; if there is, the validity 

of such back-extrapolation may need 

to be examined.

Validity of assumption of low neutron 

doses in the reactor areas needs to 

be examined.

Validity of implicit assumption that 

CTW neutron doses were lower than 

NCWs needs to be examined in view 

of the higher bioassay results for 

some periods and radionuclides, 

including plutonium in some periods.

NIOSH had stated that it has 

paired neutron and photon 

data and may issue a report 

in March 2011.

Update – February 21, 2014: This issue 

has been resolved.

This issue is resolved by the 

Board vote of Dec. 8, 2011.

19 Test reactor neutron dose NA Neither the ER nor the TBD analyzes 

the neutron dose at the Heavy Water 

Components Test Reactor. Issue of 

an incident was raised in a worker 

interview done by SC&A.

NIOSH is addressing neutron 

doses as part of issues 17 

and 18.

SC&A research did not result in any 

specific information about this accident 

(such as date and accident description).

Update – February 21, 2014: No 

information that would warrant a 

reopening of this issue has come to light 

since the last matrix update.

One SC&A interviewee 

indicated an incident took 

place at this reactor (crack 

in the core). No further 

information was available 

from the interviewee, and no 

information on such an 

incident was found in 

document research done by 

SC&A. As a result, this issue 

has been tentatively closed.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

20 Tank Farm exposure 

geometry

NA NIOSH to estimate the geometry of 

exposure in special work situations, 

such as those described in the F and 

H Area Tank Farm Fault Tree 

Databank, and the frequency with 

which these corrections may need to 

be applied to external dose. While 

correction factors can, in principle, be 

calculated, it is not clear that a 

scientifically valid set of scenarios, 

including time worked and 

radiological conditions, can be 

constructed. NIOSH has not 

addressed this issue in the ER.

NIOSH is preparing a model 

for developing adjustment 

factors due to geometry of 

exposure in the Tank Farm.

SC&A will review the NIOSH report 

when it is published.

Update – February 21, 2014: NIOSH 

has stated that it is using MCNP 

modeling to address this issue. The final 

model has not been published. This 

issue was put into a low priority since 

external dose geometry issues have 

been satisfactorily resolved in the past 

and have not been SEC issues 

(ABRWH, 2013, pp. 57–64).

A more general issue of 

geometry, and specifically 

hand exposure, has been 

raised in worker interviews. 

NIOSH is preparing a Tank 

Farm geometry report. Work 

group needs to address 

whether work beyond that is 

needed for SEC review. 

Open pan burning issue is 

not relevant since it ended in 

Feb. 1972.

21 External exposure coworker data adequacy for 

CTWs

7.2.1.3 ORAUT-OTIB-0052 (NIOSH, 2007a) 

is claimant favorable for a large 

majority of CTWs. However, it is not 

claimant favorable for some 

categories. A bounding dose (or 

better) demonstration needs to be 

made for all CTW job types.

A suitable adjustment has 

been made for all CTWs. No 

further work is needed. 

SC&A agrees that existing databases 

can be used for CTW coworker external 

dose estimation with appropriate 

adjustment. This does not include issues 

22 and 23, which do not concern 

coworker data adequacy. Refer to 

SC&A’s review of OTIB-0052 (SC&A, 

2007).

Update – February 21, 2014: This issue 

has been resolved.

No issue at this time.

22 Badges not capturing 

dose

NA SC&A worker interviews suggest that 

workers kept their badges out of 

higher radiation areas in order not to 

exceed dose limits, or sometimes 

CTWs would be in radiological 

situations without knowing it (one 

incident is described when workers 

were working with radioactive tools 

thought initially to be clean).

NIOSH will review the SC&A 

report.

SC&A prepared a report compiling 

worker issues relating to radiation dose 

as it was experienced compared to dose 

that was recorded. This includes matrix 

issue 23 (SC&A, 2011c).

Update – February 21, 2014: NIOSH 

has not responded to SC&A 2011c.

Update – March 2022: SC&A did not 

find a response or disposition on this but 

acknowledges that this is not likely an 

SEC issue.

No issue at this time.
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NOTICE: This document has been reviewed to identify and redact any information that is protected by the Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

23 External dose recording 

accuracy and 

completeness

7.3 Petitioners raised the issue of working 

conditions with high dose rates when 

badge dose may have been underrecorded or not recorded (such as 

weekend work) and/or pencil 

dosimeters were off-scale, or when 

there are zero doses in the record. An 

issue connected to this would be 

whether the HPAREH database 

reflects actual work experience. 

Petitioners also state that in some 

cases, workers thought they were 

working in clean areas that were then 

determined to be contaminated.

NIOSH will respond to the 

SC&A report.

SC&A 2011c covers both matrix issues 

22 and 23.

Update – February 21, 2014: Refer to 

update on matrix issue 22.

This issue has been merged 

with issue 22. SC&A 

prepared a single report on 

matrix issues 22 and 23.

24 Early monitoring data Various The ER has addressed lack of early 

monitoring data for many workers and 

radionuclides by a number of devices, 

including building coworker models, 

using reporting levels, using air 

monitoring data, and estimating n/p 

ratios. While each of these needs to 

be assessed in its own right (as 

described in the issues listed in this 

matrix), an overall assessment of 

early recordkeeping practices, 

adherence to procedures, and 

adequacy of data appears to be 

warranted.

NA Update – February 21, 2014: This 

matrix issue has been resolved.

This issue had been merged 

with other issues but is no 

longer an SEC issue in view 

of the Board vote on Dec. 8, 

2011.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

25 Environmental dose None Using dispersion modeling of stack 

source terms as described in the TBD 

and referred to in the ER (p. 72) is not 

appropriate for onsite SRS workers. 

For instance, thousands of gallons of 

solvents contaminated with fission 

products and plutonium were burned 

in the burning ground. Use of a 

Gaussian plume model is not 

appropriate here, especially for 

particles greater than half a micron. 

Furthermore, the resuspension factor 

does not appear to be claimant 

favorable and is not entirely 

appropriate for this class of problem. 

It may not be claimant favorable by 

three or four orders of magnitude. 

Even for stack releases, one 

potentially significant issue is the nonconservatism of the standard 

Gaussian model used in the TBD, 

where it pertains to 

“non-standardized” short-term 

releases occurring during stable 

atmospheric conditions. 

Refer to issue 14. Update – February 21, 2014: Merged 

with issue 14. This matrix issue has 

been resolved for open pan burning.

This issue has been merged 

with issue 14. Now resolved 

since open-pan burning 

stopped in Feb. 1972. Refer 

to comment for issue 14.
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Matrix issue 

no.

Issue brief ER section no. Issue description NIOSH issue status SC&A review status/update Current status 

(March 2022)

26 Additional worker and 

worker representative 

issues

NA Worker and petitioner representatives 

raised various issues during work 

group meetings and comment 

periods.

NIOSH will respond to SC&A 

report.

SC&A compiled a report detailing the 

issues raised and categorized them, with 

an indication of where the issue was 

already covered by an existing matrix 

issue (SC&A, 2011d).

Update – February 21, 2014: NIOSH 

has not provided a specific response to 

SC&A 2011d. The issues raised in 

SC&A 2011d are broadly similar to 

matrix issues 12 and 22/23 in most 

cases, but workers provided specific 

additional examples, such as lack of 

Health Physics coverage in some cases.

Update – March 2022: While a number 

of these comments are addressed in 

other SEC issues reviewed by the work 

group and NIOSH, a full response is not 

evident. SC&A acknowledges that none 

of the issues to date are of apparent 

SEC significance.

No issue at this time.
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

References for Attachment A

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Effective date: 4/22/2022 Revision No. 0 (Draft) Document No.: SCA-TR-2022-SEC001 Page 68 of 76

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

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for the Savannah River Site (ORAUT-OTIB-0081, rev. 01). 

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Effective date: 4/22/2022 Revision No. 0 (Draft) Document No.: SCA-TR-2022-SEC001 Page 69 of 76

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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

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claims for construction trade workers, revision 1. 

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evaluation report. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/2009/srsmatrix0909.pdf 

SC&A, Inc. (2010b). Review of ORAUT-OTIB-0075: Use of claimant datasets for coworker 

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and non-construction workers at Savannah River Site. 
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

SC&A, Inc. (2010d, December 10). List of exotic radionuclides at Savannah River Site and dose 

reconstruction issues associated with them in the context of the Savannah River Site construction 

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non-construction workers and the implications for coworker models at Savannah River Site. 

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significant fraction of less-than results (SCA-TR-PR2010-0009, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-oraurprt44-r0.pdf 

SC&A, Inc. (2011b). Incident records at Savannah River Site: Discussion of the Special 

Exposure Cohort issue number 12 related to incidents [Draft white paper]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srssecim12-r0.pdf 

SC&A, Inc. (2011c, January 20). Matrix issues 22 and 23 regarding petitioner external dose 

issues [Memorandum]. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srssecim012011.pdf 

SC&A, Inc. (2011d). Review of the worker comments for the May 22, 2008, Savannah River Site 

(SRS) worker outreach meeting and petitioner supporting material [Draft white paper]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srswom-r0.pdf 

SC&A, Inc. (2011e). Review of some SRS claimant cases to examine badge and area codes for 

adequacy in thorium SEC implementation [Draft white paper]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srsth-r0.pdf 

SC&A, Inc. (2013a). SC&A review of Addendum 3 to the NIOSH Savannah River Site Special 

Exposure Cohort (SEC-00103) evaluation report [Draft white paper]. 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srssec103era3-r0.pdf 

SC&A, Inc. (2013b). Review of the methods for estimating neptunium-237 intakes at the 

Savannah River Site for the period 1972–2007. 

SC&A, Inc. (2014). Issues matrix for the Savannah River Site SEC petition and petition 

evaluation report. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-srsimsec103-0214.pdf

SC&A, Inc. (2014b, June 6). SC&A’s current evaluation of the SRS SEC matrix issue 3 – 

recycled uranium [Memorandum]. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scasrssecim3-060614.pdf

SC&A, Inc. (2017). Focused review on the concurrence of ORAUT-OTIB-0081, revision 03, and 

the draft coworker implementation criteria (SCA-TR-2017-SEC005, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-tib81r3dcic-r0.pdf 
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

SC&A, Inc. (2018, October 11). SC&A review of RPRT-0070 methods for Th-232 dose 

reconstruction [Memorandum]. https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/scasrsrprt70-101118-508.pdf 

SC&A, Inc. (2020). Review of ORAUT-OTIB-0081, revision 04, “Internal coworker dosimetry 

data for the Savannah River Site” (SCA-TR-2019-SEC004, rev. 1). 

https://ftp.cdc.gov/pub/FOIAREQ/181746_red-508.pdf 

SC&A, Inc. (2021, October 25). Updated status of SEC-00103-related issues [Informal internal 

memorandum to the Savannah River Site and SEC Issues work groups]. SRDB upload pending 

Westinghouse Savannah River Corporation (WSRC). (2000). Workplan/RCRA facility 

investigation/remedial investigation report for the Old Radioactive Waste Burial Ground 643-E, 

S01-S22 (WSRC-RP-00127, Rev. 1.4), Volume I–Text and Volume II–Appendices. 

http://sti.srs.gov/fulltext/WSRC-RP-97-00127.pdf 
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Attachment B: Updated Status of SEC-00103-Related Issues

This attachment is a February 2022 update to an informal, internal memorandum that SC&A sent 

to the Savannah River Site (SRS) and SEC Issues work groups and the National Institute for 

Occupational Safety and Health (NIOSH) on October 25, 2021. SC&A updated the memo based 

on a technical call with NIOSH on January 12, 2022, and provides it here for the convenience of 

the work groups.

Much of the focus over the past 3–4 years has been on the question of bioassay completeness for 

subcontractors at SRS. Given the Advisory Board on Radiation and Worker Health’s (Board’s) 

recommendation and subsequent action by the Secretary of Health and Human Services (HHS) 

to designate a Special Exposure Cohort (SEC) class for 1972–1990 for subcontractors, SC&A 

believes it now useful to revisit the status of remaining SEC-related actions. To that end, we have 

drafted for SRS and SEC Issues work groups and NIOSH review an updated matrix of 

previously identified issues that have been addressed by the work group. The purpose is to 

achieve agreement on what issues and actions remain for SEC-00103.

The attached status and milestones are based on available reports, meeting transcripts, and notes. 

In most cases, for issues stemming from the co-exposure model reviews and radionuclidespecific issues (e.g., neptunium, thorium, and metal hydrides), NIOSH and SC&A have already 

exchanged reviews and responses and await work group discussion, review, or closure. In the 

case of subcontractor bioassay data completeness, the joint work groups have recently tasked 

SC&A with completing its review for 1991–2007. 

In terms of recent milestones, the SRS and SEC Issues work groups last met on March 23, 2021, 

to discuss the proposed SEC class for subcontractor construction trade workers (sCTWs). The 

full Board met and voted on the work groups’ proposal on April 15, 2021, with a letter 

recommending an SEC class sent to the HHS Secretary on July 12, 2021. That class was 

approved and designated by the HHS Secretary on August 18 and became effective on 

September 17, 2021. 

In terms of the other SEC issues, the SRS and SEC Issues work groups last met to discuss issues 

such as neptunium and thorium in 2017, with additional NIOSH and SC&A reports on those 

subjects issued in 2018 and 2019. 

Based on work group and NIOSH input, we will revise the attached matrix to be a basis for 

further discussion.
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distribution. 

Table B-1. Status Summary of SEC Actions: Savannah River Site (SEC-00103)

SEC issue Source documents SEC period Recent actions Status/Resolution Notes

Co-exposure 

models

OTIB-0081 (internal 

coworker dosimetry 

data):

Rev. 03: 11/22/2016

Rev. 04: 3/13/2020

Rev. 05: 9/1/2020

Construction 

trade workers 

(CTWs): 1972–

1998

sCTWs: 1991–

1998

SC&A reviewed rev. 04 

on 9/4/2019 and then 

issued a revision of that 

review on 3/13/2020 (rev. 

1 of SC&A’s review)

Work group (WG) 

closed findings 2–5 and 

all observations in 

December 2019 and 

November 2020.

Finding 1 subsumed 

under trivalent bioassay 

response (refer to next 

row)

Awaits joint SEC/SRS 

WG group action

(presentations were 

made to joint WGs on 

11/17/2020 and 

11/20/2020)

Data adequacy Trivalent bioassay 

variability (response 

papers by NIOSH and 

SC&A)

1972–1998 SC&A response:

6/3/2020

NIOSH response:

10/21/2020

SC&A and NIOSH held 

technical call in 

February 2021; 

resolution of SC&A’s 

original questions likely 

to require an SC&A site 

visit/data capture 

and/or subject matter 

expert interviews (to be 

discussed with WG). 

NIOSH to complete 

updated co-exposure 

model including 

coefficient of variation 

analysis of trivalent 

data (pending).

Presentations were 

made to joint WGs on 

11/20/2020. Awaits 

SC&A followup with a 

summary status 

memorandum for WG

discussion of the issue 

and any potential path 

forward. Also, awaits 

NIOSH statistical 

analysis of variation in 

OTIB-0081, rev. 06.

Stratification OTIB-0075: 

Construction trade 

worker (CTW) 

stratification 

refinement 

Rev. 01: 6/17/2016

1972–1998 NIOSH white paper:

5/28/2019

SC&A plutonium (Pu) 

memo:

11/12/2019

NIOSH Pu response:

3/4/2020

No further activity, other 

than status 

presentations to Board

Awaits joint SEC/SRS 

WG group action

(presentations were 

made to joint WGs 

11/17/2020 & 

11/20/2020)
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SEC issue Source documents SEC period Recent actions Status/Resolution Notes

Neptunium 

exposures 

RPRT-0065

(neptunium 

operations) 

Rev. 0: 9/19/2016

RPRT-0077 (codes)

Rev. 0: 11/8/2016

RPRT-0080

(Plutonium Fuel Form 

Facility)

Rev. 0: 2/7/2017

1972–1995

1973–1989

1973–1977

SC&A reviewed and 

NIOSH responded for all 

three reports.

SC&A’s review dates:

RPRT-0065: 3/13/2017

RPRT-0077: 4/10/2017

RPRT-0080: 8/2/2017

RPRT-0065: NIOSH 

responses to 2 SC&A 

findings (5/23/2017) 

RPRT-0077: NIOSH 

responses to all SC&A 

findings/observations 

(1/30/2018)

RPRT-0080: NIOSH 

responses to 3 SC&A 

findings (1/30/2018)

Awaits joint SRS/SEC 

WG action

Thorium 

exposures 

RPRT-0070 (Th-232)

(5/15/2017)

RPRT-0081 (thoron) 

(4/7/2017)

1972–1995 RPRT-0070: SC&A had 1 

finding (10/11/2018)

RPRT-0081: SC&A had 1 

observation (10/11/2018)

NIOSH responses to all 

findings and 

observations

RPRT-0070:

12/17/2018

RPRT-0081:

6/27/2019

Awaits joint SRS/SEC 

WG action

Metal hydrides RPRT-0072

(1/9/2017)

Early 1980s–

2007

RPRT-0072: SC&A had 

several comments 

(8/3/2018)

NIOSH responses to all 

SC&A comments 

(1/4/2019)

No findings – needs 

WG action

Bioassay data for 

DuPont-era 

subcontractors 

(RPRT-0092)

RPRT-0092

RPRT-0091

RPRT-0094

1972–1990 Board recommends SEC 

class for sCTWs 

7/12/2021

SEC class designated 

8/18/2021

SEC class effective 

9/17/2021

Bioassay data for 

Westinghouse-era 

subcontractors 

(RPRT-0092)

RPRT-0092

RPRT-0091

RPRT-0094

1991–1998 SC&A tasked Sept. 2021 To be determined Ongoing
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Index of Reports Cited in Attachment B 

OTIB-0075: National Institute for Occupational Safety and Health. (2016a). Use of claimant 

datasets for coworker modeling (ORAUT-OTIB-0075, rev. 01). 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t75-r1.pdf 

OTIB-0081: National Institute for Occupational Safety and Health. (2020a). Internal dosimetry 

co-exposure data for the Savannah River Site (ORAUT-OTIB-0081, rev. 05). 

https://www.cdc.gov/niosh/ocas/pdfs/tibs/or-t81-r5-508.pdf 

RPRT-0065: National Institute for Occupational Safety and Health. (2016b). An evaluation of 

neptunium operations at Savannah River Site (ORAUT-RPRT-0065, rev. 00). 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-65-r0.pdf 

RPRT-0070: National Institute for Occupational Safety and Health. (2017a). Evaluation of 

method for assessment of thorium-232 exposures at the Savannah River Site from 1972 to 1989

(ORAUT-RPRT-0070, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-70-

r0.pdf 

RPRT-0072: National Institute for Occupational Safety and Health. (2017b). Locations of stable 

metal tritide use at the Savannah River Site (ORAUT-RPRT-0072, rev. 00). 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-72-r0.pdf 

RPRT-0077: National Institute for Occupational Safety and Health. (2016c). Evaluation of 

Health Physics Area and Health Physics Department codes to identify neptunium workers at the 

Savannah River Site (ORAUT-RPRT-0077, rev. 00). 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-77-r0.pdf 

RPRT-0080: National Institute for Occupational Safety and Health. (2017c). Potential 

neptunium exposure to plutonium fuel facility construction workers in Building 235-F at the 

Savannah River Site (ORAUT-RPRT-0080, rev. 00). 

https://ww.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-80-r0.pdf 

RPRT-0081: National Institute for Occupational Safety and Health. (2017d). Appropriateness of 

using 1997 gross alpha air sampling data as a method of bounding thoron intakes at the SRS H 

Area Tank Farm between 1972 and 1994 (ORAUT-RPRT-0081, rev. 00). 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-81-r0.pdf

RPRT-0091: National Institute for Occupational Safety and Health. (2019a). Evaluation of 

Savannah River Site americium-241 source terms between 1971 and 1999 using bioassay 

frequency tables (ORAUT-RPRT-0091, rev. 00). 

https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-91-r0-508.pdf

RPRT-0092: National Institute for Occupational Safety and Health. (2019b). Evaluation of 

bioassay data for subcontracted construction trade workers at the Savannah River Site

(ORAUT-RPRT-0092, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-92-

r0-508.pdf
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Privacy Act 5 U.S.C. § 552a and has been cleared for distribution. 

RPRT-0094: National Institute for Occupational Safety and Health. (2019c). Bioassay for 

subcontractor construction trade workers at the Savannah River Site from 1972 to 1997

(ORAUT-RPRT-0094, rev. 00). https://www.cdc.gov/niosh/ocas/pdfs/orau/oraurpts/or-rprt-94-

r0-508.pdf 

Trivalent Bioassay Variability:

National Institute for Occupational Safety and Health. (2020b). Response to SC&A 

memorandum, “Summary position on trivalent bioassay variability” [Response paper]. 

https://ftp.cdc.gov/pub/FOIAREQ/183766-508.pdf 

SC&A, Inc. (2020, June 3). Summary position on trivalent bioassay variability [Memorandum]. 

https://ftp.cdc.gov/pub/FOIAREQ/181759-508.pdf